Post on 08-Aug-2015
$100$36,000
/ DAY PER EMPLOYEE
UP TO
PENALTIES FOR NON-
COMPLIANCE
/ YEAR
1954
§105 ADDED TO INTERNAL REVENUE CODE
Section 105 allows an employer to offer a plan to reimburse employees’ qualifiedmedical expenses, including insurance premiums.
Amounts received excluded from employees’ income.
1961
REVENUE RULING 61-146
Allows an employer to informally pay for or reimburse an employee’s “premium for hospital and medical insurance,” tax-free, under IRC Section 106.
Known today as an Employer Payment Plan.
1974
EMPLOYER RETIREMENT INCOME SECURITY ACT (ERISA)
ERISA establishes fair and equal treatment requirements for employee benefit plans, supported by formal plan documents.
1996
EMPLOYEE MEDICAL PRIVACY LAW (HIPAA)
HIPAA creates national standards to protect individual’s medical records and other personal health information, including insurance premiums.
2002
NOTICE 2002-45 (HRAs)
The IRS Notice confirms an employer can offer a plan to reimburse employees’ qualified medical expenses, including insurance premiums.
Known today as a Health Reimbursement Arrangement (HRA).
2006
ZANE BENEFITS INTRODUCES HRAs
ZaneHRA offers employers a formal plan to reimburse employees’ qualifiedout-of-pocket medical expenses,including insurance premiums.
2010
AFFORDABLE CARE ACT (ACA)
The ACA introduces sandardized health insurance to all Americans and requires grouphealth plans to comply with newrequirements effective January 1, 2014.
2013
NOTICE 2013-54
In coordination with the Dept. of Labor, the IRS confirms all group health plans, including HRAs and Employer Payment Plans, may not place limits on essential health benefits and must cover basic preventive healthcare services without costsharing.
Confirmed that Employer Payment Plans will not comply with the ACA Market Reforms.
2014
ZANE BENEFITS INTRODUCES HEALTHCARE REIMBURSEMENT PLANS (HRPs)
Offers employers a formal plan (ZaneHealth) that continues to complywith IRS and ERISA requirements, inaddition to new ACA Market Reforms (PHS Act 2711 and 2713).
Effective for plan start dates beginning January 1, 2014.
HOW ZANEHEALTH COMPLIES
www.ZaneBenefits.com
Can employers still reimburse employees for individual health insurance premiums?
Yes!
How?
ZaneHealth offers employers a compliant health insurance reimbursement plan.
AFFORDABLE CARE ACT To comply with ACA reforms, ZaneHealth:
» Does not place an annual or lifetime limit on Essential Health Benefits (EHB).
» Provides coverage for basic preventive care without cost-sharing.
» Provides automated compliance with new administrative and reporting requirements.
IRSTo comply with IRS rules, ZaneHealth:
» Automatically generates custom and accurate Plan Documents.
» Ensures compliance with documentation and non-discrimination rules.
HIPAATo comply with HIPAA Privacy Rules, ZaneHealth:
» Reviews all reimbursement requests so the employer does not come in regular contact with Protected Health Information (PHI).
ERISATo comply with ERISA, ZaneHealth:
» Generates custom Summary Plan Descriptions (SPDs).
» Follows ERISA rules in regards to individual health insurance reimbursement.
Learn more at :
COMPLIANCE TIMELINE
HOW ZANEHEALTH WORKS
The company uses ZaneHealth to give
employees a monthly healthcare allowance.
Employees purchase their own health plan
and submit a reimbursement
request. ZaneHealth reviews the request.
The company reimburses employees
via payroll, check, or direct deposit, up to
their available balance.
ZaneHealth is...
» A group health plan.
» A Section 105 Healthcare Reimbursement Plan (HRP).
» A compliant plan, structured to comply with all applicable federal regulations, including the new ACA Market Reforms.
ZaneHealth is not...
» An Employer Payment Plan.
» A Health Reimbursement Arrangement (HRA).
Could employers pay penalties if the plan does not comply with federal regulations? Yes
2014
DEPT. OF LABOR FAQ
In the FAQ, the Dept. of Labor reconfirms that premium reimbursement arrangements, such as HRPs, are group health plans.
Emphasized compliance with the ACA Market Reforms.
Understanding ZaneHealth Compliance