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Special Compliance Alert: What Is the Impact of the Roe v. Wade Reversal?

… in environment, improvement of morale, or general improvement of health, even if the trip is made on the advice of a doctor are not includable. Travel Benefits to Obtain Abortion Services Travel to obtain abortion services may be provided as part of the health plan, through a Health Reimbursement Arrangement (HRA), through a Flexible Spending Account (FSA), or through a Health Savings Account (HSA) for individuals enrolled in a High Deductible Health Plan (HDHP). Providing travel and lodging expenses for abortions outside of these types of arrangements could result in the creation of a group health plan because the …

https://www.epicbrokers.com/insights/special-compliance-alert-roe-v-wade-reversal-impact/

Leverage Forward-Thinking Insurance Solutions to Boost Your Recruiting Efforts

… employee demographics while managing medical cost inflation and relieving your HR team to focus on employee recruiting and engagement. Our experienced Employee Benefits team can assist with: Managing escalating pharmacy costs to offer candidates more coverage options Identifying solutions that meet your candidates where they are (remote or hybrid working arrangements, new to the workforce, aging parents, or nearing retirement) Developing professional benefits communications to share with potential employees early in the recruiting process Navigating complex and ever-changing human resource compliance requirements. EPIC can help you stand out in a crowded space to attract and secure top talent with …

https://www.epicbrokers.com/insights/boost-your-recruiting-efforts/

Compliance Alert: Machine-Readable TiC File Requirement Is Looming

… the Departments released another set of FAQs providing technical guidance on MRFs and providing two safe harbors for group health plans and issuers who use alternative payment arrangements. Machine-Readable Files As part of the TiC, non-grandfathered group health plans and insurance issuers must make available to the public three separate machine-readable files (MRFs) related to: Negotiated rates for all covered items and services between the plan or issuer and in-network providers. Historical payments to, and billed charges from, out-of-network (OON) providers. For privacy purposes, historical payments must have a minimum of twenty entries …

https://www.epicbrokers.com/insights/compliance-alert-tic-file-requirement/

IRS Releases 2023 HSA & HDHP Limits

Quick Facts The Internal Revenue Service (IRS) updates High Deductible Health Plans (HDHP) and Health Savings Account (HSA) limits annually for inflation. In May 2022, the IRS released Revenue Procedure 2022-24 updating cost-sharing limits for HDHPs, maximum HSA contribution limits and the maximum amount that may be made available for an excepted benefit Health Reimbursement Arrangement (HRA) in 2023. Overview The IRS recently released Revenue Procedure 2022-24, which includes the 2023 inflation-adjusted amounts for HSAs, HDHPs and excepted benefit HRAs. These limits include the maximum HSA contribution limit, the minimum deductible amount for HDHPs, the maximum …

https://www.epicbrokers.com/insights/irs-releases-2023-hsa-hdhp-limits/

USERRA Benefits Requirements

… long as coverage is continued by the employee. NOTE: Even if the spouse and dependents do not have independent continuation rights under USERRA, they may qualify for independent coverage rights under COBRA. The definition of a “health plan” for this purpose is broad, including major medical plans, as well as other health plans such as health Flexible Spending Accounts (FSAs), Health Reimbursement Arrangements (HRAs), dental, and vision. Coverage continuation is not required for non-health benefits. The employer responsibility for contributions is set forth in 38 United States Code (USC) §4317(a) and differs a bit depending upon the …

https://www.epicbrokers.com/insights/userra-benefits-requirements/

Additional Guidance for Health Plan Coverage of OTC COVID-19 Tests

… following requirements:  Implement a process of direct payment to the preferred (i.e. in-network) pharmacies or retailers so that the participant is not required to submit a claim for reimbursement; and  Offer a “direct-to-consumer” shipping program that can be provided through an internet, mail or phone order arrangement and can be offered through a vendor or relationship separate from the health plan itself. The new FAQs recognize that there may be supply shortages, but as long as the plan offers a direct-to-consumer program, the plan can still limit reimbursement for out-of-network tests to …

https://www.epicbrokers.com/insights/additional-guidance-for-health-plan-coverage-of-otc-covid-19-tests/

DOL Provides Q&As for CAA Broker Compensation Disclosure Requirements

The Consolidated Appropriations Act (CAA), signed into law on December 27, 2020, included a requirement that starting December 27, 2021, brokers and consultants supplying services to Employee Retirement Income Security Act (ERISA) group health plans disclose to plan fiduciaries (typically the plan sponsor), in writing, direct and indirect compensation they receive for providing services to such plans. This disclosure requirement was effective for “contracts or arrangements entered into, extended, or renewed on or after December 27, 2021.” See our Compliance Insights article, “Employee Benefits Broker Compensation Disclosure Requirements Are Coming Soon,” for more information. On Thursday, December 30, 2021, the …

https://www.epicbrokers.com/insights/dol-provides-qas-caa-broker-compensation-disclosure-requirements/

Thoughts on Law Firm Engagement Letters

… that up front. Of course, before relying on any form of conflicts waiver, the lawyer should be satisfied that the conflict is one that can be waived and that the likelihood of the lawyer having to withdraw mid-matter to the detriment of one or more clients is not unduly high. Matter/File Closings and Obligations  Many if not most lawyers employ language that specifies the number of years after which the firm will or may destroy documents unless the client makes different arrangements in writing. File storage costs being what they are, this saves time and confusion at a

https://www.epicbrokers.com/insights/law-firm-engagement-letters/