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So far Jason Jappa has created 31 entries.

Legal Alert: Congress Passes Law Expanding use of HRAs by Small Employers

On December 7, 2016, the Senate passed the 21st Century Cures Act (“Cures Act”), an omnibus measure that includes the Small Business Healthcare Relief Act (“Relief Act”), which significantly expands small employers’ options for providing health coverage. The Cures Act passed both houses of Congress by a wide margin and the President has indicated that he will sign it into law. Once signed, the law will be effective for plan years beginning on or after January 1, 2017. The Relief Act is Title XVIII of the Cures Act and starts on page 824.

The HRA Relief Act allows small employers—defined as those who are not applicable large employers (“A.L.E.s”)—to establish a qualified health reimbursement arrangement (“HRA”) that reimburses eligible employees and their family members for medical expenses, including individual health insurance premiums, up to a specified annual limit. In general, an employer is an A.L.E. if it employed at least 50 full-time equivalent employees on average in the prior calendar year. […]

By |December 9th, 2016|Compliance, Legislation|Comments Off on Legal Alert: Congress Passes Law Expanding use of HRAs by Small Employers

Legal Alert: Judge Blocks Overtime Rule Set to Take Effect December

The case, State of Nevada v. DOL, was presided over by Judge Amos Mazzant, an Obama appointee to the United States District Court for the Eastern District of Texas.  The lawsuit was filed by the Attorneys General for Texas and Nevada and was joined by 19 other states.  The states alleged that the DOL’s overtime rule is illegal because […]

By |November 23rd, 2016|Compliance|Comments Off on Legal Alert: Judge Blocks Overtime Rule Set to Take Effect December

Legal Alert: IRS Provides a 30-Day Extension for Furnishing Forms 1095 and Extends Good Faith Transition Relief

The Internal Revenue Service (IRS) has released Notice 2016-70, which extends the deadline for furnishing Forms 1095-B and 1095-C to individuals from January 31, 2017 to March 2, 2017.  The Notice did not delay the due date for filing the forms with the IRS, which remains February 28 if filing by paper, or March 31 if filing electronically.

The instructions to Forms 1094-C and 1095-C provide that employers can request a 30-day extension to furnish statements to individuals by sending a letter to the IRS that includes the reason for delay.  However, because the Notice’s extension of time to furnish the forms is more generous […]

By |November 21st, 2016|Compliance|Comments Off on Legal Alert: IRS Provides a 30-Day Extension for Furnishing Forms 1095 and Extends Good Faith Transition Relief

Legal Alert: Post-Election Returns: What Now Obamacare?

The votes have been counted and Donald Trump is the president-elect and Republicans control Congress.  Among the many questions around the proverbial watercooler is what now for “Obamacare”?  While it is impossible for anyone to predict the future, we undertake to make a short, best guess about the future of the Affordable Care Act (“ACA”).

As a candidate, Mr. Trump repeatedly vowed to “repeal and replace” the ACA.   So, the first question is, inevitably […]

By |November 15th, 2016|Employee Benefits, Health Care Reform, Legislation|Comments Off on Legal Alert: Post-Election Returns: What Now Obamacare?

Legal Alert: IRS Increases Health FSA Contribution Limit for 2017, Adjusts Other Benefit Limits

On October 25, 2016, the Internal Revenue Service (IRS) released Revenue Procedure 2016-55, which raised the health Flexible Spending Account (FSA) salary reduction contribution limit to $2,600 for plan years beginning in 2017. The Revenue Procedure also released the cost-of-living (COLA) adjustments that apply to dollar limitations in certain […]

By |November 1st, 2016|Uncategorized|Comments Off on Legal Alert: IRS Increases Health FSA Contribution Limit for 2017, Adjusts Other Benefit Limits

Department of Labor Compliance Assistance

You receive a letter in the mail notifying you that your company is being audited by the Department of Labor. Once the shock wears off you immediately start thinking back, is my benefit plan in compliance, did that last notice about the ACA go into effect, did I make the update, what about fines and penalties, am I subject to those? Why was my company selected to be audited? Instead of staying up at night worrying about whether your organization is […]

By |October 17th, 2016|Uncategorized|Comments Off on Department of Labor Compliance Assistance

EMPLOYER ALERT – IRS EMAIL SCAM

The newest scam involving a fraudulent email notice from the Internal Revenue (IRS) may have your employees coming to you asking about their insurance coverage for […]

By |September 28th, 2016|Human Resources, Uncategorized|Comments Off on EMPLOYER ALERT – IRS EMAIL SCAM

Legal Alert: Enrollment Counts for Transitional Reinsurance Fee Due Nov. 15, 2016

Employers with self-insured major medical plans are reminded to report their membership count to the U.S. Department of Health and Human Services (“HHS”) via the pay.gov website by November 15, 2016, as part of the Affordable Care Act’s (“ACA”) transitional reinsurance fee (the “Fee”) […]

By |September 20th, 2016|Compliance, Employee Benefits, Human Resources|Comments Off on Legal Alert: Enrollment Counts for Transitional Reinsurance Fee Due Nov. 15, 2016

One Question Makes a Big Difference: Is your broker simply shopping your medical program, or utilizing actuarial analysis?

The real issue is how do you know if you are over paying for your medical plan? When we hear that companies are not using an actuary we ask another simply question: How do you know you are not overpaying? Where’s the analysis? We’ve yet to hear a convincing explanation. How can you or your broker possibly know, because they aren’t trained or qualified to interpret incurral factors, group specific trend and expected large claims versus actual as an actuary is, so they can’t know if there is an argument to be made. […]

By |August 26th, 2016|Employee Benefits, Employee Benefits Adviser|Comments Off on One Question Makes a Big Difference: Is your broker simply shopping your medical program, or utilizing actuarial analysis?

Legal Alert: DOL Proposes Changes to Annual Reporting for ERISA Plans

The U.S. Department of Labor (DOL) recently proposed revisions to Form 5500 (Annual Return/Report for Employee Benefit Plan), the related schedules, and the rules that govern the forms. In general, these changes would first apply for the 2019 plan year, although certain changes may be implemented earlier. These proposed revisions were published on July 21, 2016, and comments are being accepted for 75 days, through October 4.

The proposed revisions are intended to “modernize the financial statements and investment information filed about employee benefit plans; update the reporting requirements for service provider fee and expense information; enhance accessibility and usability […]

By |July 28th, 2016|Compliance, Employee Benefits, Human Resources, Legislation|Comments Off on Legal Alert: DOL Proposes Changes to Annual Reporting for ERISA Plans