State Income Tax Imputation

in Affordable Care Act, Tax Issues

While health plans are required to provide coverage up to age 26 for dependent children, several states have not adopted the updated Internal Revenue Code in order to make this coverage tax-free.  This means that for about a dozen states income imputation for dependent child coverage will be required for state income tax purposes.  However, keep in mind that the existing dependent rules of a qualifying child (under age 24 and a full time student) or a qualifying relative (any age but the...Continue Reading

HHS Issues MLR Interim Final Rules

in Affordable Care Act

This morning HHS issued the long-awaited MLR interim final regulations.  In prior posts, I discussed that insured mini-med plans and insured expatriate plans have been asking for an exception from these new requirements.  Unfortunately, the interim regulations do not contain a blanket exception.  However, the interim regulations do require an insurer to seperately report aggregate premium and expenditure data for expatriate plans and mini-med plans.  (Mini-med is defined by HHS as a...Continue Reading

What Will the State Exchanges Look Like?

in Affordable Care Act

Although many plan sponsors are still trying to digest the 2011 changes, some are looking toward the future when the exchanges are scheduled to come on line in 2014.  HHS is planning on issuing proposed regulations starting in the Spring of 2011 addressing the basic exchange requirements.  However, for now HHS has issued a general statement to the states seeking to establish an exchange.  This guidance was posted late last week at the following address:

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Annual Limit Waiver Applications – Update

in Affordable Care Act

I recently talked to HHS regarding an annual limit waiver (i.e., mini-med waiver) that i filed on behalf of a client.  HHS requested additional information, which is not new.  But, what is new, is that one of the additional pieces of requested information is a hypothetical calculation of premiums for the next year, assuming that the plan sponsor had to raise the annual limit to $750,000.  Theoretically, this sounds like good information for HHS to request.  But, this information takes...Continue Reading

Agencies Amend Grandfather Plan Rules

in Affordable Care Act

Today, the agencies amended the grandfather plan rules to allow employers to change insurers without losing grandfather status.  Under the prior interim final rules, one of the ways an employer group health plan could lose its grandfather status was if the employer changed insurers.  However, as amended, employers can now change insurers without losing grandfather status, so long as the structure of the coverage doesn’t violate one of the other rules for maintaining grandfathered plan...Continue Reading