• Interim Final Regulations for Early Retiree Reinsurance Program

  • Chart of Small Group Market Premiums Helps Determine Small Employer Health Insurance Credit

  • No Changes to HSA Contribution Limits for 2011

  • Proposed Legislation Will Likely Extend COBRA Subsidy Eligibility through the End of the Year

  • IRS Issues Interim Final Rules Relating to Dependent Coverage of Children to Age 26


Interim Final Regulations for Early Retiree Reinsurance Program

Earlier this month, interim final regulations were released for the Early Retiree Reinsurance Program created by the Affordable Care Act (health care reform).  They can be found at http://edocket.access.gpo.gov/2010/pdf/2010-10658.pdf.

This is a temporary program with limited funding of $5 billion, and no one knows how long those funds will last.  Accordingly, plans seeking reimbursement should file early. If you have a plan that provides health coverage to early retirees, please talk to your Cowan account manager.



Chart of Small Group Market Premiums Helps Determine Small Employer Health Insurance Credit

The Affordable Care Act created a federal income tax credit to eligible small employers that make nonelective contributions towards their employees' health insurance premiums under an arrangement that meets certain requirements.  For taxable years beginning before 2014, the amount of the credit is based on a percentage of the lesser of: 1) the amount of nonelective contributions paid by the eligible small employer on behalf of employees under the arrangement during the taxable year, and 2) the amount of nonelective contributions the employer would have paid under the arrangement if each such employee were enrolled in a plan that had a premium equal to the average premium for the small group market in the state (or area in the state) in which the employer is offering health insurance coverage. 

To determine the average premium for part 2 of the calculation, the IRS has released a chart that lists the average premium for the sma ll group market for each state for the 2010 taxable year, as determined by Health and Human Services.  The chart can be found at http://www.irs.gov/pub/irs-drop/rr-10-13.pdf.

Additional guidance can be found at http://www.irs.gov/pub/irs-drop/n-10-44.pdf.



No Changes to HSA Contribution Limits for 2011

The IRS announced that the contribution limits for HSAs, as well as the deductible and out-of-pocket limits for HDHPs, will remain the same for the 2011 calendar year.  This is due to the fact that the cost of living has been fairly static.  The limits are as follows:  

2011 Annual HSA Contribution Limits

Self-only $3,050
Family $6,150

2011 Annual HDHP Limits
  Self-only Family
Minimum Deductible $1,200 $2,400
Maximum Out-of-pocket $5,950 $11,900


Proposed Legislation Will Likely Extend COBRA Subsidy Eligibility Through the End of the Year

Earlier this month, Congress released "The American Jobs and Closing Tax Loopholes Act of 2010" which, if passed, will extend eligibility for the COBRA premium subsidy through December 31, 2010. Lawmakers are expected to bring the legislation to a vote before Memorial Day. 

http://waysandmeans.house.gov/media/pdf/111/America_Jobs_Summary.pdf


 

IRS Issues Interim Final Rules Relating to Dependent Coverage of Children to Age 26

Regulations issued in May by the IRS clarify certain matters related to the implementation of regulations under The Affordable Care Act regarding coverage eligibility for dependents until age 26.  The interim final rules make clear that all dependents under age 26 must be offered coverage, regardless of student status, financial dependency, living arrangements, or employment.  Also, a plan or issuer cannot deny or restrict coverage based on eligibility for other coverage.  The only exception to this is for grandfathered group health plans with plan years beginning before January 1, 2014.  These plans are not obligated to offer coverage to an adult child under age 26 who is eligible for coverage under another employer-provided group health plan (not including their parents' employer-provided plans).  Neither of the parents' plans, grandfathered or not, could deny coverage based on the child's eligibility for the other parent's plan.  In addition, plan terms and coverage (including premium) may not vary based on age.

These rules go into effect for plan years beginning on or after September 23, 2010; however, some carriers are already extending dependent coverage to varying degrees.  If you have questions about how this affects your group health plan, please call your Cowan account manager.

Click here for Q&A from the IRS