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Wednesday, July 9, 2025

HSA & FSA Enhancements in Reconciliation Bill

Great news for those who rely on qualified healthcare spending accounts like HSAs and FSAs, to help with healthcare and dependent daycare expenses!  The recently passed H.R.1, 2025 reconciliation bill, otherwise referred to as the “The One Big Beautiful Bill Act”, contains important enhancements affecting both HSAs and FSAs.  Importantly, these expansions take affect beginning in 2026, providing plenty of time for affected individuals to plan accordingly for 2026 open enrollment.  Here’s what the bill changed for both Health Savings Accounts (HSA) and Flexible Spending Accounts (FSA) –

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Monday, March 17, 2025

Rx Data Collection Deadline Looms

The Consolidated Appropriations Act (CAA) of 2021 includes a provision known as Prescription Drug Data Collection, or RxDC.  Each year, insurance companies and employers are required to remit data to the U.S. Departments of Health and Human Services, Labor, and Treasury pertaining to certain aspects of their health insurance offering

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Wednesday, January 22, 2025

ACA Employer Mandate Filing Relief…Finally!

After ten long years of the Affordable Care Act’s (ACA) so called employer shared responsibility (aka employer mandate) reporting requirements, we finally have some relief!   The former President signed two bills on December 23, 2024, that significantly ease the burden associated with this particular aspect of ACA compliance – the Paperwork Burden Reduction Act and the Employer Reporting Improvement Act.  Here’s what the ACA’s ALE’s (Applicable Large Employer) need to know and do, to benefit from the relief provided by these two bills…

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Tuesday, September 17, 2024

Inflation Reduction Act Impact on Medicare Part D

This fall, the annual Medicare open enrollment season could look considerably different than in previous years.  That’s because of the Inflation Reduction Act’s (IRA) new, $2,000 cap on out of pocket costs associated with prescription drugs covered by Medicare Part D.  While the out of pocket cap reduction (down from $3,300 in 2024) sounds good on the surface, speculation is that Medicare Part D health insurers will look for ways to offset the benefit upgrade.  Here’s what to look for in the coming weeks – 

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Friday, October 27, 2023

Gag Clause Prohibition ~ Compliance Requirement

The Consolidated Appropriations Act (CAA) requires an annual “gag clause prohibition compliance attestation” (GCPCA) be submitted by Dec. 31, 2023, and annually hereafter.  Importantly, carriers/administrators/payers have largely removed any references to gag clauses and prohibitions of sharing pricing and quality data, which was prohibited by the CAA. 

Friday, June 6, 2014

Employers Reimbursing Employees for Individual Coverage

Recently, the IRS issued guidance which places harsh penalties on employers that deploy the strategy of “dumping” employees into the Individual health insurance marketplace. The guidance followed the White House's objection to the idea of allowing employers the ability to provide employees with a lump sum of money with which to buy individual insurance on the exchange/marketplace. This builds on guidance released last year from the Department of Labor (DOL) which was more broad in scope. A previous blog post addressed the DOL guidance, which effectively “killed” the ability to use tax preferred funds from HRAs and FSAs to fund Individual health insurance premiums, regardless of the source of such coverage.

Wednesday, December 4, 2013

Health Insurance and the Tax Code

For years, politicians, policy wonks, and various health insurance stakeholders have debated the merits of how the tax code encourages employer provided coverage, yet seemingly discourages the individual purchase of coverage outside of the workplace.
The primary example of this confounding situation is the fact that health insurance is tax deductible to an employer, yet not so to an individual who purchases coverage on their own, outside of the workplace. There are numerous tax incentives and benefits available to individuals who purchase health insurance, but virtually all of these incentives are attached to the purchase…

Wednesday, November 13, 2013

FSA Rollover…An Early Christmas Present From the IRS!

When people hear or see the acronym IRS they generally do not associate it with gift giving. But that is precisely what the IRS delivered on October 31, 2013 in the form of Notice 2013-71, which allows for a partial carryover of unused FSA funds (click – http://www.irs.gov/pub/irs-drop/n-13-71.pdf). The often cited “use it or lose it” rule deters many otherwise eligible Flexible Spending Account (FSA) enrollees from setting aside funds on a pre-tax basis for future use. However, with the issuance of Notice 2013-71, the IRS is allowing the option of a rollover of up to $500 at the end of the FSA plan year, even for 2013 plan years! This is great news for FSA plan participants and employers alike.