February 2020 | SSG Compliance Recap

February was a busy month in the employee benefits world.

The Centers for Medicare and Medicaid Services (CMS) released an updated Premium Assistance Under Medicaid and the Children’s Health Insurance Program (CHIP) model notice. CMS also issued frequently asked questions (FAQs) regarding its recently issued summary of benefits and coverage (SBC) template for plan years beginning on or after January 1, 2021.

The Department of Health and Human Services (HHS) released a bulletin that allows grandmothered plans to be extended through 2021. The Internal Revenue Service (IRS) released an opinion letter stating that collection of employer shared responsibility penalties under the Patient Protection and Affordable Care Act (ACA) is not subject to a statute of limitations. The IRS also released an information letter confirming that a cafeteria plan is not required to recognize the permitted election change events under the cafeteria plan regulations.

The Department of Labor (DOL) issued an opinion letter addressing whether a general partner’s limited partnership programs constitute ERISA employee welfare benefit plans. CMS issued a proposed rule on calculating and imposing civil monetary penalties when a group health plan fails to comply with Section 111 Medicare Secondary Payer (MSP) reporting requirements. CMS published a bulletin regarding states seeking to restrict excepted benefit health reimbursement arrangements (EBHRAs) from reimbursing short-term, limited-duration insurance (STLDI) premiums.

IN THIS ISSUE:

• CMS Releases Updated Premium Assistance under Medicaid and the Children’s Health Insurance Program (CHIP) Model Notice
• CMS Issues FAQs on the Updated SBC Template
• HHS Releases Bulletin that Extends Grandmothered Plans Through 2021
• IRS Releases an Opinion Letter on the Collection of Employer Shared Responsibility Penalties
• IRS Releases Information Letter on Cafeteria Plan Permitted Election Change Events
• DOL Releases an Opinion Letter on Limited Partnership Employee Welfare Benefit Plans
• CMS Releases Proposed Rule on Civil Monetary Penalties for Medicare Secondary Payer Reporting Failures
• CMS Publishes Bulletin on State Restrictions on EBHRAs
• Question of the Month

CONTINUE READING this SSG Compliance Recap to learn more.