Posts Categorized: Wellness Programs

Good News for Affordability and Wellness

in Affordable Care Act, Wellness Programs

As background, the employer penalty regulations provide that coverage under an employer plan is affordable to a particular employee if the employee’s “required contribution” to the plan does not exceed 9.5% of the employee’s income for the year. However, the regulations are unclear as to what is included in the “required contribution” when it comes to wellness surcharges and penalties. As an initial matter, because the affordability test looks to the annual premium paid for employee-only coverage, surcharges not related to employee-only coverage are disregarded. For example, a typical spouse/partner surcharge should be excluded from the affordability calculation. Further, a… Continue Reading

HHS Proposed Regulations – Wellness Plans

in Affordable Care Act, Wellness Programs

This morning HHS released three separate proposed regulations for public inspection. The official copies of the proposed regulations are scheduled to be included in the Federal Register for November 26th. This first group is just the tip of the iceberg. Much more guidance is expected over the next 3-4 months. However, an air of mystery surrounds the most important piece of guidance that was released this morning – the nondiscrimination rules for wellness plans. 1. Guaranteed Availability and Renewability of Coverage. [Link] This proposed rule would implement the Affordable Care Act’s policies related to fair health insurance premiums, guaranteed availability,… Continue Reading

On-Site Clinics

in Health Benefits, Wellness Programs

Many employers are looking toward on-site clinics to reduce costs. At the same time, if not properly structured, on-site clinics can lead to medical liability, HIPAA privacy and HDHP issues. See the attached article for what employers are doing now. Clinic Article

SBC Reminder

in Affordable Care Act, Wellness Programs

I recently spoke at the ECFC meeting last week – with one of the major topics being SBCs. It is important to keep in mind that seperate SBCs will be needed for the following arrangements: 1. Stand-alone HRAs. 2. Integrated HRAs where the HRA is seperately administered (i.e., not administered by the insurer). 3. Employee Assistance Programs (EAPs) where the EAP is providing assessment or treatment. In these situations, significant revisions will be needed to the SBC template, so that the SBC works for these arrangements and is not misleading. However, you still need to retain the outline of the… Continue Reading