EBIA Weekly Newsletter

Are the Section 1557 Language-Assistance Requirements the Same as the Requirements for SBCs and Claims?

   February 22, 2018

QUESTION: We are an employer sponsor of an insured major medical plan, and we have heard that Section 1557 of the Affordable Care Act (ACA) imposes language-assistance requirements on our plan. Are the language-assistance requirements under the Section 1557 nondiscrimination rule different from the “culturally and linguistically appropriate manner” standard that applies to the summary … Read More

EBIA Seminars Are Coming to a City Near You!

   February 15, 2018

These full- and half-day intermediate-level courses cover ERISA, the ACA, cafeteria plans, HRAs & HSAs, HIPAA, COBRA—and a brand-new course on wellness programs! Join us in Boston (May 8–11), Minneapolis (May 15–18), Seattle (June 5–8), Dallas (June 12–15), or Chicago (June 19–22)! Our early bird discount is available through February 28, 2018. Read More

IRS Updates Guidance on Employer Shared Responsibility, Including 2018 Penalty Amounts

   February 15, 2018

Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act Available at https://www.irs.gov/affordable-care-act/employers/questions-and-answers-on-employer-shared-responsibility-provisions-under-the-affordable-care-act The IRS has updated Q&A guidance on its webpage relating to Code § 4980H employer shared responsibility for applicable large employers (ALEs). Here are highlights: 2018 Adjusted Penalty Amounts. In Q/A-54, the IRS has announced … Read More

Updated MSP User Guide Addresses New Medicare Beneficiary Identifiers for Reporting

   February 15, 2018

MMSEA Section 111 MSP Mandatory Reporting GHP User Guide, Version 5.0 (Dec. 15, 2017) Available at https://www.cms.gov/Medicare/Coordination-of-Benefits-and-Recovery/Mandatory-Insurer-Reporting-For-Group-Health-Plans/Downloads/New-Downloads/MMSEA-Section-111-GHP-User-Guide-Version-50.pdf The most recent version of CMS’s Medicare Secondary Payer (MSP) User Guide provides guidance on using the new Medicare Beneficiary Identifier (MBI) for MSP mandatory reporting purposes. As background, CMS is in the process … Read More

DOL Issues 2017 Form M-1 for MEWA Reporting

   February 15, 2018

Form M-1 (2017) Available at https://www.dol.gov/sites/default/files/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/forms/m1-2017.pdf The DOL has released the 2017 Form M-1, which is used by certain entities to report compliance with group health plan mandates in Part 7 of ERISA, including some health care reform requirements. The form must be filed by multiple employer welfare arrangements (MEWAs) providing … Read More