Many in the health insurance and employee benefits space are claiming to have found the next new, innovative and sure fire way to reduce health insurance costs. Actually its an old idea, originally deployed in the retirement/pension area of the overall employee benefits palette, and fairly recently resurrected for use in employer provided health insurance. The next “silver bullet”?
(Remember 401(k)s gradual replacement of many defined benefit retirement pension plans in the eighties?)
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.
There is an old expression – “Figures don’t lie, liars do figure”. We all rely on data for various purposes, and the health care industry is no exception in its use of data to explain, defend, describe, or refute various measures. In fact, there is a relatively quiet movement underway to establish health care standards to better enable providers to utilize a standardized, “best practices” method of delivering care. If you want to understand this movement better, google – “patient centered outcomes research institute” or PCORI, and check it out. (By the way, the Affordable Care Act (ACA) requires health insurers and self funded plans to fund the PCORI at a rate of $2 per insured member per year in 2014.)
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…
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.