As open enrollment season closes and 2019 approaches, making sure that all compliance items are in order is of the utmost importance. The key to successfully transitioning through another year is to be organized and prepare ahead of time for changes.
The Center for Consumer Information and Insurance Oversight (CCIIO) recently issued a number of new guidance documents ahead of the 2019 open enrollment period. Those, combined with other regulatory changes and resources, help compile a compliance checklist that brokers can use to make sure they are on the right track for 2019.
Grandfathered Plan Status
A grandfathered plan is one that was already in existence when the Affordable Care Act (ACA) was enacted in 2010. However, certain changes to plans will negate their grandfathered status. This does not affect all plans, but there is some documentation that’s required for plans that are affected. Be sure to confirm these changes and any required documentation during open enrollment.
Health Coverage Changes
Coverage plans and details are always subject to reform, so it’s important to understand what is changing from year to year. For example, within the past few years, healthcare coverage was extended for dependents up until the age of 26. These important changes could affect enrollees and their families, so it’s important to know all the updates so you can educate participants.
FSA and HSA Limits
The IRS recently announced Revenue Procedure 2018-57, which states the changes to FSA and HSA limits based on inflation and cost-of-living increases. In summary:
- Annual healthcare Flexible Spending Account (FSA) contribution limits will increase $50 from the current amount of $2,650 to $2,700.
- Monthly limit for transit and parking will increase from $5 from the current amount of $260 to $265.
- Annual maximum reimbursement for a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) will increase $100 for individual coverage from the current amount of $5,050 to $5,150, and the maximum reimbursement amount will increase $200 for family coverage from the current amount of $10,250 to $10,450.
- The limit for individual coverage for HSAs will increase $50 from $3,450 to $3,500, and the family coverage contribution will increase $100 from $6,900 to $7,000.
ERISA Requirements
Title I of the Retirement Income Security Act (ERISA) sets the standards to make sure employee benefit plans are established and administered properly. The documentation required under ERISA is extremely important, since the Department of Labor can launch an ERISA audit on your clients at any time.
There are a few steps to maintaining ERISA compliance:
- Research what types of plans are subject to ERISA.
- Develop documentation to help your clients educate their employees.
- Create an ERISA wrap document to help clients maintain compliance without depleting HR resources.
Bonus: Trending Benefits
Although it’s not directly a compliance item, it’s always a good idea to know what benefits are trending upward, as well as which ones are fading from the spotlight. That way, you can help clients put together a benefit package that truly makes sense and identify what other compliance items you need to take care of. Right now, top trending benefits to watch include:
- Student loan repayment programs.
- Extended parental leave.
- Commuter benefits.
- Health and wellness programs.
Be sure to research your clients’ locations and key demographics to get a deeper look into the benefits they would be most likely to want.
These are just a few items to add to your compliance checklist, but they can offer you a good start to 2019 planning.
Sources:
https://www.healthaffairs.org/do/10.1377/hblog20180726.755850/full/
https://cdn2.hubspot.net/hubfs/1860314/Employee%20Benefits%20Compliance%20Checklist%20for%20Large%20Employers.pdf?t=1511381389777
https://www.benefitspro.com/2018/11/29/employee-benefit-trends-to-watch-in-2019/
