26 February 2018 By

For prescription drug plans that renewed on January 1, 2018, the deadline for the on-line filing to the Centers for Medicare & Medicaid Services (CMS) is February 28, 2018.  This deadline is within 60 days after the beginning date of the plan year.
Group health plan sponsors are required to disclose to CMS whether their prescription drug coverage is creditable or non-creditable.  In general, a group health plan’s prescription drug coverage is considered creditable if its actuarial value equals or exceeds the actuarial value of the Medicare Part D prescription drug coverage.

The disclosure must be made to CMS on an annual basis, and upon any change that affects whether the coverage is creditable. More specifically, the Medicare Part D disclosure notice must be provided within the following timeframes:

  *   Within 60 days after the beginning date of the plan year for which the entity is providing the disclosure to CMS;
  *   Within 30 days after the termination of a plan’s prescription drug coverage; and
  *   Within 30 days after any change in the plan’s creditable coverage status.

Plan sponsors are required to use the online disclosure form at

Please refer to the attached Legislative Brief for additional details and let me know if you have any questions.

23 January 2018 By

Impact of Tax Bill

The tax bill signed into law on December 22, 2017, eliminates the tax penalty for individuals who fail to maintain minimum essential coverage (MEC) as of January 1, 2019. Although this change will affect individuals who decline to enroll in health coverage, it does not eliminate employer reporting requirements. Some important considerations:

  *   The individual mandate penalties are still in force in 2018. Individuals who go without health coverage for 3 months or longer in 2018 will still have to pay a penalty (unless they qualify for an exception).
  *   The employer mandate still applies. Applicable large employers (ALEs) will continue to face penalties for failure to offer affordable coverage providing minimum value to their full-time employees.
  *   The section 6055 and 6056 reporting requirements continue to apply. Applicable large employers, employers of any size that provide self-funded and level-funded plans, and insurance carriers are still required to issue the applicable 1095 forms and file those forms with the IRS.

27 December 2017 By

I hope you had a wonderful holiday.  Last week, the Internal Revenue Service (IRS) issued Notice 2018-06 to:

  *   Extend the due date for furnishing forms under Sections 6055 and 6056 for 2017 for 30 days, from January 31, 2018, to March 2, 2018; and
  *   Extend good-faith transition relief from penalties related to 2017 information reporting under Sections 6055 and 6056.

However, Notice 2018-06 does not extend the due date for filing forms with the IRS for 2017. The due date for filing with the IRS under Sections 6055 and 6056 remains February 28, 2018 (April 2, 2018, if filing electronically).

The attached ACA Bulletin outlines the new due date and additional guidance in this notice.

Please let me know if you have any questions.

Barry E. Fields
Vice President, Employee Benefits

Cell: 908-406-7000 | Fax: 732-834-0233
101 Crawfords Corner Road, Suite 1300, Holmdel, NJ 07733

16 October 2017 By

December 20, 2017 - A few hours ago both the U.S. Senate and the U. S. House of Representatives passed the tax reform bill called the Tax Cuts and Jobs Act.  The bill is expected to be signed into law by President Trump by the end of the day today.
While the bill includes many aspects that will have substantial impact on businesses, the tax reform bill does not affect the following tax provisions:

  *   Tax treatment of employer-sponsored health plans; and

  *   The ACA’s Cadillac tax on high-cost employer-sponsored health coverage.

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