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DOL Issues Final Rules on Multiple Employer Welfare Arrangements

The U.S. Department of Labor (?Ç£DOL?Ç¥) recently released final rules intended to curb abuses of some multiple employer welfare arrangements (?Ç£MEWAs?Ç¥) by imposing additional reporting requirements on MEWAs and by enhancing DOL?ÇÖs enforcement authority. ?áUnder the final rules, all MEWAs that provide medical benefits, even if not a group health plan, must electronically file a Form M-1 annually, which now requires more extensive financial information than the prior version.?á Additionally, all employee welfare plans that file a Form M-1 must also file a Form 5500, even if the plan would otherwise be exempt, to demonstrate the plan?ÇÖs compliance with the Form M-1 filing requirement.?á Failure to answer the Form M-1 compliance question will cause the Form 5500 to be rejected as incomplete, which may subject the filer to civil penalties.?á The deadline for filing this year?ÇÖs Form M-1 has been extended to May 1, 2013.?á The final rules also enhance… Continue Reading

HHS Final Rule Regarding Notice of Benefit and Payment Parameters for 2014

The U.S. Department of Health and Human Services (?Ç£HHS?Ç¥) recently issued the Notice of Benefit and Payment Parameters, a final rule which (1) expands on standards defined in prior rules regarding the permanent risk adjustment, transitional reinsurance, and temporary risk corridors programs under the Patient Protection and Affordable Care Act (?Ç£PPACA?Ç¥) (collectively, the ?Ç£Risk Programs?Ç¥) and (2) sets out payment parameters for the Risk Programs. The Risk Programs become effective in 2014 and are intended to reduce the incentives for health insurance issuers to avoid enrolling higher-risk individuals, such as those with pre-existing medical conditions, by transferring funds from insurers with lower-risk enrollees to insurers who cover higher-risk populations. Notably for group health plan sponsors, this final rule (i) confirms which types of health insurance coverage and self-funded health plans are excluded from making contributions under the transitional reinsurance program (the ?Ç£TRP?Ç¥) (which is effective only for 2014, 2015, and… Continue Reading

March 2013