CHIP Notice Update (2019)

Since 2009, special enrollment rights to immediately enroll in an employer’s health plan arise if an individual becomes eligible for a state premium assistance subsidy under Medicaid or the Children’s Health Insurance Program Reauthorization Act (“CHIPRA”, or often shortened to CHIP). The subsidy helps low-income individuals pay for employer coverage, transferring them from government-sponsored health programs to employer health plans. CHIPRA imposes a notice requirement on employers who maintain health plans with participants residing in one or more states providing a premium assistance subsidy. The notice must be provided annually to all employees residing in each premium assistance subsidy state, including employees not enrolled in the plan.

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Posted on August 05, 2019 by Gary B. Kushner, SPHR, CBP, President and CEO

Student Loan Repayments and 401(k) Match

In a Private Letter Ruling (PLR), the IRS has recently sort of, kind of, maybe, in special circumstances enabled employers to make a matching contribution to their 401(k) plan on behalf of eligible plan participants who, instead of contributing to the 401(k), make certain qualifying student loan repayments instead.

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Posted on October 18, 2018 by Gary B. Kushner, SPHR, CBP, President and CEO

IRS Plays Emily Litella Regarding 2018 HSA Family Contributions

In May, 2017, the IRS released the 2018 HSA contributions limits in Rev Proc 2017-37, amongst other HSA-related indexed numbers, stating that the maximum contribution for those in family HDHP coverage would be $6,900. Congress then passed its Reconciliation Act in December, 2017, changing the indexing methodology for a number of benefit-related (and other) limits to utilize something called “chained-CPI,” as opposed to the regular CPI that had been used for decades. This in turn caused the IRS to recalculate its 2018 limits for benefit plans, and on March 2, 2018 issued Rev Proc 2018-18, retroactively reducing the 2018 family HSA maximum contribution amount by $50 to $6,850.

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Posted on April 26, 2018 by Gary B. Kushner, SPHR, CBP, President and CEO

Rules for Posting an SPD on Company Intranet Site

We’re often asked if an employer can post a plan’s Summary Plan Description (SPD) on its company’s intranet website. The answer is a qualified yes, as long as certain rules are followed. The Department of Labor (DOL) provides a safe harbor for electronic disclosure of plan documents including the use of an intranet. The safe harbor sets forth general requirements for all electronic disclosures and additional requirements for recipients that do not have computer access at work.

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Posted on September 15, 2016 by Gary B. Kushner, SPHR, CBP, President and CEO

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