Do you offer coverage to your employees through a self-insured group health plan? Do you sponsor a Health Reimbursement Arrangement (HRA)? If so, do you know whether your plan or HRA is subject to the annual Patient-Centered Research Outcomes Institute (PCORI) fee?

This article answers frequently-asked questions about the PCORI fee, which plans are affected, and what you need to do as the employer sponsor. PCORI fees for 2017 health plans and HRAs are due July 31, 2018.

What is the PCORI fee?

The Affordable Care Act (ACA) created the Patient-Centered Outcomes Research Institute to study clinical effectiveness and health outcomes. To finance the nonprofit institute’s work, a small annual fee is charged on health plans.

Most employers do not have to take any action, because most employer-sponsored health plans are provided through group insurance contracts. For insured plans, the carrier is responsible for the PCORI fee and the employer has no duties.

If, however, you are an employer that self-insures a health plan or an HRA, it is your responsibility to determine whether PCORI applies and, if so, to calculate, report, and pay the fee.

The annual PCORI fee is equal to the average number of lives covered during the health plan year, multiplied by the applicable dollar amount:

  • If the plan year end date was between January 1 and September 30, 2017: $2.26.
  • If the plan year end date was between October 1 and December 31, 2017: $2.39.

Payment is due by July 31 following the end of the calendar year in which the plan year ended. Therefore, for plan years ending in 2017, payment is due no later than July 31, 2018.

Does the PCORI fee apply to all health plans?

The fee applies to all health plans and HRAs, excluding the following:

  • Plans that primarily provide “excepted benefits” (e.g., stand-alone dental and vision plans, most health flexible spending accounts with little or no employer contributions, and certain supplemental or gap-type plans).
  • Plans that do not provide significant benefits for medical care or treatment (e.g., employee assistance, disease management, and wellness programs).
  • Stop-loss insurance policies.
  • Health savings accounts (HSAs).

The IRS provides a helpful chart indicating the types of health plans that are, or are not, subject to the PCORI fee.

If I have multiple self-insured plans, does the fee apply to each one?

Yes. For instance, if you self-insure one medical plan for active employees and another medical plan for retirees, you will need to calculate, report, and pay the fee for each plan. There is an exception, though, for “multiple self-insured arrangements” that are sponsored by the same employer, cover the same participants, and have the same plan year. For example, if you self-insure a medical plan with a self-insured prescription drug plan, you would pay the PCORI fee only once with respect to the combined plan.

Does the fee apply to HRAs?

Yes. The PCORI fee applies to HRAs, which are self-insured health plans, although the fee is waived in some cases. If you self-insure another plan, such as a major medical or high deductible plan, and the HRA is merely a component of that plan, you do not have to pay the PCORI fee separately for the HRA. In other words, when the HRA is integrated with another self-insured plan, you only pay the fee once for the combined plan.

On the other hand, if the HRA stands alone, or if the HRA is integrated with an insured plan, you are responsible for paying the fee for the HRA.

What about QSEHRAs? Does the fee apply?

Yes. A Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) is new type of tax-advantaged arrangement that allows small employers to reimburse certain health costs for their workers. Although a QSEHRA is not the same as an HRA, and the rules applying to each type are very different, a QSEHRA is a self-insured health plan for purposes of the PCORI fee. In late 2017, the IRS released guidance confirming that small employers that offer QSEHRAs must calculate, report and pay the PCORI fee.

Can I use ERISA plan assets or employee contributions to pay the fee?

No. The PCORI fee is an employer expense and not a plan expense, so you cannot use ERISA plan assets or employee contributions to pay the fee. An exception is allowed for certain multi-employer plans (e.g., union trusts) subject to collective bargaining. Since the fee is paid by the employer as a business expense, it is tax deductible.

How do I calculate the fee?

Multiply $2.26 or $2.39 (depending on the date the plan year ended in 2017) times the average number of lives covered during the plan year. “Covered lives” are all participants, including employees, dependents, retirees, and COBRA enrollees. You may use any one of the following counting methods to determine the average number of lives:

  • Average Count Method: Count the number of lives covered on each day of the plan year, then divide by the number of days in the plan year.
  • Snapshot Method: Count the number of lives covered on the same day each quarter, then divide by the number of quarters (e.g., four). Or count the lives covered on the first of each month, then divide by the number of months (e.g., 12). This method also allows the option — called the “snapshot factor method” — of counting each primary enrollee (e.g., employee) with single coverage as “1” and counting each primary enrollee with family coverage as “2.35.”
  • Form 5500 Method: Add together the “beginning of plan year” and “end of plan year” participant counts reported on the Form 5500 for the plan year. There is no need to count dependents using this method since the IRS assumes the sum of the beginning and ending of year counts is close enough to the total number of covered lives. If the plan is employee-only without dependent coverage, divide the sum by 2. (If Form 5500 for the plan year ending in 2017 is not filed by July 31, 2018, you cannot use this counting method.)

For an HRA, count only the number of primary participants (employees) and disregard any dependents.

How do I report and pay the fee?

Use Form 720, Quarterly Excise Tax Return, to report and pay the annual PCORI fee. Report all information for self-insured plan(s) with plan year ending dates in 2017 on the same Form 720. Do not submit more than one Form 720 for the same period with the same Employer Identification Number (EIN), unless you are filing an amended return.

The IRS provides Instructions for Form 720. Here is a quick summary of the items for PCORI:

  • Fill in the employer information at the top of the form.
  • In Part II, complete line 133(c) and/or line 133(d), as applicable, depending on the plan year ending date(s). If you are reporting multiple plans on the same line, combine the information.
  • In Part II, complete line 2 (total).
  • In Part III, complete lines 3 and 10.
  • Sign and date Form 720 where indicated.
  • If paying by check or money order, also complete the payment voucher (Form 720-V) provided on the last page of Form 720. Be sure to fill in the circle for “2nd Quarter.” Refer to the Instructions for mailing information.

Caution! Before taking any action, confirm with your tax department or controller whether your organization files Form 720 for any purposes other than the PCORI fee. For instance, some employers use Form 720 to make quarterly payments for environmental taxes, fuel taxes, or other excise taxes. In that case, do not prepare Form 720 (or the payment voucher), but instead give the PCORI fee information to your organization’s tax preparer to include with its second quarterly filing.

Summary

If you self-insure one or more health plans or sponsor an HRA, you may be responsible for calculating, reporting, and paying annual PCORI fees. The fee is based on the average number of lives covered during the health plan year. The IRS offers a choice of three different counting methods to calculate the plan’s average covered lives. Once you have determined the count, the process for reporting and paying the fee using Form 720 is fairly simple. For plan years ending in 2017, the deadline to file Form 720 and make your payment is July 31, 2018.

Originally posted on thinkhr.com

Friday, April 27, the Internal Revenue Service (IRS) announced that the 2018 annual contribution limit to Health Savings Accounts (HSAs) for persons with family coverage under a qualifying High Deductible Health Plan (HDHP) is restored to $6,900. The single-coverage limit of $3,450 is not affected.

This is the final word on what has been an unusual back-and-forth saga. The 2018 family limit of $6,900 had been announced in May 2017. Following passage of the Tax Cuts and Jobs Act in December 2017, however, the IRS was required to modify the methodology used in determining annual inflation-adjusted benefit limits. On March 5, 2018, the IRS announced the 2018 family limit was reduced by $50, retroactively, from $6,900 to $6,850. Since the 2018 tax year was already in progress, this small change was going to require HSA trustees and recordkeepers to implement not-so-small fixes to their systems. The IRS has listened to appeals from the industry, and now is providing relief by reinstating the original 2018 family limit of $6,900.

Employers that offer HSAs to their workers will receive information from their HSA administrator or trustee regarding any updates needed in their payroll files, systems, and employee communications. Note that some administrators had held off making changes after the IRS announcement in March, with the hopes that the IRS would change its position and restore the original limit. So employers will need to consider their specific case with their administrator to determine what steps are needed now.

HSA Summary

An HSA is a tax-exempt savings account employees can use to pay for qualified health expenses. To be eligible to contribute to an HSA, an employee:

  • Must be covered by a qualified high deductible health plan (HDHP);
  • Must not have any disqualifying health coverage (called “impermissible non-HDHP coverage”);
  • Must not be enrolled in Medicare; and
  • May not be claimed as a dependent on someone else’s tax return.

HSA 2018 Limits

Limits apply to HSAs based on whether an individual has self-only or family coverage under the qualifying HDHP.

2018 HSA contribution limit:

  • Single: $3,450
  • Family: $6,900
  • Catch-up contributions for those age 55 and older remains at $1,000

2018 HDHP minimum deductible (not applicable to preventive services):

  • Single: $1,350
  • Family: $2,700

2018 HDHP maximum out-of-pocket limit:

  • Single: $6,650
  • Family: $13,300*

*If the HDHP is a nongrandfathered plan, a per-person limit of $7,350 also will apply due to the ACA’s cost-sharing provision for essential health benefits.

 

Originally posted on thinkHR.com

Taking control of health care expenses is on the top of most people’s to-do list for 2018.  The average premium increase for 2018 is 18% for Affordable Care Act (ACA) plans.  So, how do you save money on health care when the costs seems to keep increasing faster than wage increases?  One way is through medical savings accounts.

Medical savings accounts are used in conjunction with High Deductible Health Plans (HDHP) and allow savers to use their pre-tax dollars to pay for qualified health care expenses.  There are three major types of medical savings accounts as defined by the IRS.  The Health Savings Account (HSA) is funded through an employer and is usually part of a salary reduction agreement.  The employer establishes this account and contributes toward it through payroll deductions.  The employee uses the balance to pay for qualified health care costs.  Money in HSA is not forfeited at the end of the year if the employee does not use it. The Health Flexible Savings Account (FSA) can be funded by the employer, employee, or any other contributor.  These pre-tax dollars are not part of a salary reduction plan and can be used for approved health care expenses.  Money in this account can be rolled over by one of two ways: 1) balance used in first 2.5 months of new year or 2) up to $500 rolled over to new year.  The third type of savings account is the Health Reimbursement Arrangement (HRA).  This account may only be contributed to by the employer and is not included in the employee’s income.  The employee then uses these contributions to pay for qualified medical expenses and the unused funds can be rolled over year to year.

There are many benefits to participating in a medical savings account.  One major benefit is the control it gives to employee when paying for health care.  As we move to a more consumer driven health plan arrangement, the individual can make informed choices on their medical expenses.  They can “shop around” to get better pricing on everything from MRIs to prescription drugs.  By placing the control of the funds back in the employee’s hands, the employer also sees a cost savings.  Reduction in premiums as well as administrative costs are attractive to employers as they look to set up these accounts for their workforce.  The ability to set aside funds pre-tax is advantageous to the savings savvy individual.  The interest earned on these accounts is also tax-free.

The federal government made adjustments to contribution limits for medical savings accounts for 2018.  For an individual purchasing single medical coverage, the yearly limit increased $50 from 2017 to a new total $3450.  Family contribution limits also increased to $6850 for this year.  Those over the age of 55 with single medical plans are now allowed to contribute $4450 and for families with the insurance provider over 55 the new limit is $7900.

Health care consumers can find ways to save money even as the cost of medical care increases.  Contributing to health savings accounts benefits both the employee as well as the employer with cost savings on premiums and better informed choices on where to spend those medical dollars.  The savings gained on these accounts even end up rewarding the consumer for making healthier lifestyle choices with lower out-of-pocket expenses for medical care.  That’s a win-win for the healthy consumer!

With the election of a new President, health care plans and the fate of the Affordable Care Act are a hot topic of discussion. As part of his 7-tier health plan, President-Elect Donald Trump has proposed a shift in the way health savings accounts (HSAs) are offered to working Americans. Simply put, an HSA is a savings account for medical expenses. They are tax advantaged accounts an individual can open in addition to their current health plan to pay out-of-pocket expenses ranging from co-pays to surgery deductibles. Typically, HSAs have been offered to individuals with high deductible health plans (HDHPs). However, if the President-Elect’s new health plan strategy is enacted, an HDHP would no longer be an eligibility requirement, significantly impacting healthcare options for millions of Americans.

HSA vs. FSA – Which one is right for you?

When choosing a savings account for medical expenses there are two options: HSAs and FSAs. Each type of account is generally non-taxable for qualified medical expenses, except under certain circumstances in which a medical expense was incurred prior to opening an HSA, and each is accumulated by contributions from your paycheck. Some employers offer HSA and FSA matching contributions.

In the past, there have been some prominent differences between health savings accounts and flexible spending accounts (FSAs). Traditionally, FSAs have been the option for those who choose health plans with low deductibles. The money you contribute from your paycheck into your FSA account must be spent within the year, and cannot be rolled over. Conversely, you must have an HDHP to open an HSA, and funds accumulated from paychecks can be rolled over into the next year if left unused.

Accumulating tax advantages have made HSAs more popular and beneficial in comparison to FSAs. When it comes to changing jobs, HSAs typically are not affected, while FSAs are impacted due to restrictions in rollover of funds. However, FSAs do not have eligibility requirements, which have made them more widely available to individuals.

What’s Next? How HSAs would change under Trump’s health plan

Trump’s new health plan would make HSAs readily available to everyone by removing the HDHP eligibility requirements that are currently in place. In addition to this drastic barrier removal, Trump has said he will change policy to allow families to share the accounts between one another. Any contribution or interest-earned by an HSA is tax-deductible, and individuals with HSAs can withdrawal money tax-free for certain medical expenses ranging from transplants to acupuncture. The combination of these three tax-advantages creates an unmatched savings option for those who choose HSAs. While Trump has said he will change some factors of HSAs, he plans to keep these tax advantages.

Who will benefit from the new HSA model?

In the past, HSAs have been more attractive for retirees. Health care costs tend to rise in the retirement stage of life, which makes an HSA a more cost-efficient option for retirees. Since individuals are allowed to take out money for medical expenses without being taxed, retirees have the potential to save large amounts of money in the later stages of their life. However, under Trump’s proposed plan, HSAs will also become increasingly attractive for younger people. Because individuals will continue to be allowed to roll over money contributed to their HSA in a given year into the next, young and healthy people will be able to save sizable amounts for use later in life.

While much remains to be seen about which aspects of President-Elect Trump’s health plan will be enacted when he takes office, take the time now to educate yourself on how an HSA can work for you.

By Nicole Federico and Kate McGaughey

Over the past few years, we have seen the cost of health care steadily increase – a trend supported by the latest data from the 2016 UBA Health Plan Survey. During the recession, employers implemented health plans with higher copays, higher deductibles, or offered multiple plans with a variety of deductibles and pushed the cost of the lower deductible plans onto employees in an attempt to keep their costs for offering coverage at the same rate or less.

We also saw the introduction of high deductible consumer-driven health plans (CDHPs), some that also offered the option of depositing money on a tax-free basis into a health savings account (HSA) that could be used to pay for qualified medical expenses.

The HSA plans were very attractive, as many offered 0% coinsurance once the $2,000 or $3,000 deductible had been met and were priced well below other more traditional health plans. The expectation being if the consumer was paying all of their medical costs for the first few thousand dollars, they would be less likely to actively consume health care unless necessary.

It was also a way for employers to reduce premium costs by offering a high deductible plan, and fund an HSA account that an employee could use to pay for qualified medical expenses and essentially self-fund most of the up-front costs to the employee for the medical plan. In many cases, employers were able to offer a richer medical plan by combining the medical plan with HSA contributions, and still save money over their current traditional health plan costs.

What the insurance carrier actuaries did not realize was the impact this funding of the health plan consumer costs was going to have on the utilization of the health plans by the plan members. These low premium health plans were essentially “blown up” with heavy utilization, and the premiums went up so that the carriers could cover the cost of the claims and services being provided.

The insurance carriers are trying to do everything they can to keep premium costs from rising while still keeping the plan benefits within the confines of what the Patient Protection and Affordable Care Act (ACA) says must be covered. It is a balancing act, and one that is not moving in favor of the employees and their dependents.

Plan copays for office visits are holding steady, but deductibles and out-of-pocket maximums are on the rise as are prescription drug copays, which are shifting more and more of the costs to employees and their families. Some carriers are dramatically changing their prescription drug formulary lists, deleting many of the drugs they covered previously, adopting more tiers of prescription drugs, implementing co-insurance instead of copays for higher-cost specialty drugs, and raising copays in all tiers.

Furthermore, the 2016 UBA Health Plan Survey has also shown a reduction in employer funding toward HSAs for employees this past year, and employers are asking employees to take on more and more of the insurance premiums, which again translates into higher costs for employees.

www.originally published by www.ubabenefits.com

 

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