On June 24, 2019, the President issued his Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First. The Executive Order directs regulators to take action to improve healthcare price transparency and to enhance consumer-driven healthcare. The success of consumer-driven healthcare is dependent on patients being able to act as
IRS Increases Maximum Employee Contribution to Health Care FSAs for 2015
The IRS announced yesterday that the maximum annual employee contribution to a health care flexible spending account plan is increasing by $50 to $2,550 for 2015 (up from the $2,500 limit that has applied since 2013).
Employers that sponsor health care FSAs should take this increase into account in preparing for open enrollment, and may…
Agencies Release Guidance on HRAs, FSAs, and Employer Payment Plans
By James Napoli & Stacy Barrow on
On Friday, September 13, 2013, the IRS released Notice 2013-54 and the DOL issued Technical Release 2013-03 in substantially identical form. This guidance, which is generally effective January 1, 2014, provides much needed clarification on the application of certain provisions of the Patient Protection and Affordable Care Act (“ACA”) (annual limits and preventive care) to account-based plans such as HRAs and FSAs, and other types of arrangements that reimburse premiums (referred to in the guidance as “Employer Payment Plans”).
The guidance indicates that the agencies are generally viewing HRAs, FSAs, and Employer Payment Plans as group health plans for purposes of ACA. This means that these arrangements will qualify as “minimum essential coverage” for covered employees (i.e., they will preclude employees from receiving a premium credit), unless they are “excepted benefits” under HIPAA. This also means that these arrangements will need to comply with ACA’s annual dollar limit prohibition and preventive care requirements, unless they are integrated with a compliant group health plan (or are excepted benefits).