You probably already know beginning in 2014, a waiting period cannot exceed 90 days. This has been recently clarified to mean that first of the month after 90 days (for a waiting period) will be a violation of the Healthcare Reform law.
What this really means, as well, if an employer has a premium only plan document that states anything mor...e than the 90 day requirement and changes that waiting period so they are compliant, they will need a new POP plan document, etc. If the plan document is not updated and an audit occurs, with the plan being found ineligible...all of the pre-tax benefits received by the employer and employees could be in jeopardy.
Just something to consider when having the conversation with your groups about the waiting period.
Health information is considered to be personally identifiable if it relates to a specifically identifiable individual:
1. Health care claims or health care encounter information, such as documentation of doctor's visits and notes made by physicians and other provider staff;
2. Health care payment and remittance advi...ce;
3. Coordination of health care benefits;
4. Health care claim status;
5. Enrollment and disenrollment in a health plan;
6. Eligibility for a health plan;
7. Health plan premium payments;
8. Referral certifications and authorization;
9. First report of injury;
10. Health claims attachments.
ANSWER: Here are the rules about the COBRA premium (it is allowed).http://www.irs.gov/publications/p15b/ar02.html#en_US_2012_pu...blink1000193641
COBRA premiums. The exclusion for accident and health benefits applies to amounts you pay to maintain medical coverage for a current or former employee under the Combined Omnibus Budget Reconciliation Act of 1986 (COBRA). The exclusion applies regardless of the length of employment, whether you directly pay the premiums or reimburse the former employee for premiums paid, and whether the employee's separation is permanent or temporary.
Actuarial Value Bulletin Allows for State Flexibility and Accommodates CDHC Plans On Friday, the Department of Health and Human Services (HHS) released a bulletin
that describes their approach to valuing plans that will be offered in the small and individual markets after January 1, 2014. HHS’s proposed approach to the actuarial value requirements established by PPACA would be to create a national standardized approach to determining a plan’s actuarial value (AV) and develop a national “actuarial value calculator" to score plans based on their included benefits.
Summaries of Benefits and Coverage (SBC) - rules released on the NEW benefit summary that will need to be released for HRA/HSA/FSA. We will be working with our customers to be sure their plans are in compliance. http://eforerisa.wordpress.com/
QUESTION: My benefits card transaction ended up being an ineligible expense? How do I handle so that my card isn't deactivated?
ANSWER: You have a couple different options when this occurs:
The most common option is to submit a larger claim that has occurred within the correct plan year and we will offset the amount, then reimburse whatever is left.
Another option is to mail us a check for the amount of the ineligible expense and we will apply it to your account.
The last option is to have the provider refund the benefits card directly, however, keep in mind that you will still need to pay the provider with another form of payment. Call us with any questions!
A terminated employee wants to know why their Benefits Card doesn't work when they have money left over.
REASON: Typically and based on the plan document, a terminated employee can only incur expenses to the point of the term date or through the end of the month of active employment. Which is why the card is turned "off" on that date so further transactions are not paid outside the allowable incurred date.
The ex-employee does have a run out date to turn in claims from the term date though. But that is only for expenses incurred after the plan started and the term date.