Two companion interim final rules issued by the U.S. Departments of Health and Human Services, Treasury, and Labor expand exemptions related to the Affordable Care Act requirement that non-grandfathered group health plans provide coverage without cost-sharing for contraceptive services (referred to as the "contraceptive mandate"). Previously, the contraceptive mandate was subject to exemptions for religious employers and accommodations for certain other non-profit religious organizations and closely held for-profit entities with sincerely held religious beliefs against certain contraceptives.
The new rules exempt entities that object to establishing, maintaining, providing, offering, or arranging (as applicable) coverage, payments, or a plan that provides coverage or payments for some or all contraceptive services based on their sincerely held religious beliefs or moral convictions. For this purpose, the term "contraceptive services" includes contraceptive or sterilization items, procedures, or services, or related patient education or counseling.
Exempt entities will not be required to comply with a self-certification process. However, where an exemption applies and all or a subset of contraceptive services are omitted from a plan's coverage, otherwise applicable ERISA disclosures must reflect the omission of coverage in ERISA plans
Beginning Oct. 1, 2017, all Hartford HealthCare Hospitals, ancillary providers and employed physicians are considered Out of Network for patients with Anthem commercial, exchange and Medicare Advantage plans.
What Does This Mean?
Any services provided by Hartford Hospital will be considered Out of Network Services; Services will apply to out of network deductibles, out of network coinsurance and may result in overall higher out of pocket costs.
Continuation of Care through Hartford HealthCare Hospital:
Alternative Facilities of Care:
the IRS released final forms related to IRC Section 6056 reporting. The instructions are still in draft format. The final forms appear to have no substantial changes from the 2016 forms.
The most notable change is that no Section 4980H transition relief is available beginning with the 2017 reporting year. Thus, all references to such relief have been removed. Specifically, boxes B and C on Line 22 of the Form 1094-C (which were previously used to claim transition relief) have now been marked as “reserved.” Similarly, column (e) of Part III of the Form 1094-C has also been marked “reserved.”
As a reminder, PPACA requires employers (including self-insured, fully insured and uninsured) with 50 or more full-time-equivalent employees to file Forms 1094-C and 1095-C with the IRS and to provide statements to employees to comply with IRC Section 6056 (meant to help the IRS enforce the employer mandate). Specifically, large fully insured employers will need to complete and submit Forms 1094-C and 1095-C (Parts I and II). Large self-insured employers subject to both Sections 6055 and 6056 may combine reporting obligations by using Form 1094-C and completing all sections of Form 1095-C (Parts I, II and III). Small self-insured employers would need to file Forms 1094-B and 1095-B. Employers with grandfathered plans must comply with the reporting requirements as well.
Finally, as a reminder on reporting deadlines for the 2017 calendar year, the deadline to provide information returns to employees or responsible individuals is Jan. 31, 2018. Also, employers filing 250 or more forms must file electronically with the IRS. Employers filing fewer than 250 forms may file by paper or electronically. Paper filings are due by Feb. 28, 2018. Those filing electronically must report by April 2, 2018 (March 31, 2018 falls on a Saturday).
The IRS released final forms related to IRC Section 6055 reporting. The instructions are still in draft format. The final forms appear to have no substantial changes from the 2016 forms.
As a reminder, Forms 1094-B and 1095-B (the forms used for Section 6055 reporting) are required of insurers and small self-insured employers providing minimum essential coverage. These reports will help the IRS to administer and enforce PPACA’s individual mandate. Form 1095-B, the form distributed to the covered employee, will identify the employee, any covered family members, the group health plan and the months in 2016 for which the employee and family members had minimum essential coverage (MEC) under the employer's plan. If the plan is fully insured, Form 1094-B identifies the insurer (for a fully insured plan) or the employer (for a self-insured plan) and is used by the insurer to transmit corresponding Forms 1095-B to the IRS.
Please note that a completed Form 1095-B must be distributed to covered employees/individuals by Jan. 31, 2018, for the 2017 reporting year. The Forms 1095-B, along with the transmittal Form 1094-B, must be filed with the IRS by Feb. 28, 2018, if filing by paper and April 2, 2018 (March 31, 2018 falls on a Saturday), if filing electronically.
On Sept. 26, 2017, Senate Majority Leader Mitch McConnell announced that the Senate will not be holding a vote on the Graham-Cassidy plan to repeal and replace the PPACA due to dwindling support. Senators Lindsey Graham (R-SC) and Bill Cassidy (R-LA) unveiled a revised version of their legislation to repeal and replace the PPACA in hopes of winning a few more votes, before the reconciliation clock ran out on Sept. 30, 2017. Those hopes were dashed when a preliminary Congressional Budget Office (CBO) report said that the proposed bill would result in millions fewer people having comprehensive health insurance and when pivotal Republican senators declared their opposition.
most of the changes in the bill affected the individual and small group market, making only slight changes to the large group market. Specifically, the bill would have eliminated the employer mandate penalties (also likely impacting employer reporting requirements, at least in terms of simplification), without a corresponding change to the employer-sponsored coverage tax benefit. Most employers would have likely approved of the changes made to HSAs, as described more fully below. However, the chances of passage quickly became a long shot with several key Republican senators voicing their opposition to the bill. As a quick reminder, the Senate was using the budget reconciliation process to pass the bill (thereby only needing 50 votes, which is 10 votes less than would generally be required to pass a bill). Additionally, the provisions of a reconciliation bill generally must relate to or influence the budget, meaning they drive or otherwise impact federal revenue.
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