2022 Cost-Sharing Limits; HDHP Out-of-Pocket Limits and Deductibles

A non-grandfathered group health plan’s in-network out-of-pocket maximum for essential health benefits (EHBs) for the 2022 plan year cannot exceed $8,700 for self-only coverage and $17,400 for other-than self-only coverage. This is an increase of approximately 1.8% percent from 2021.

The in-network out-of-pocket maximum applies to all individuals, regardless of whether an individual has a self-only plan or other-than single coverage. Self-funded group health plans are not required to cover EHBs. But, if they do, they cannot impose lifetime or annual dollar limits on those benefits.

For high-deductible health plans (HDHPs) for the 2022 plan year, the out-of-pocket limit will be $7,050 for self-only coverage ($50 more than for 2021) and $14,100 for other-than self-only coverage ($100 more than for 2021). The minimum deductible is not changing from 2021, remaining $1,400 for self-only coverage and $2,800 for other-than self-only coverage.

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Employers to Receive PCORI Fee Mailing

Employers with a self-funded health benefit plan that are required to pay the Patient-Centered Outcomes Research Institute (PCORI) fee will be sent on Friday, June 18, a letter via mail providing their group’s “average covered lives” during the plan year ending in 2020 (using the Snapshot Count method).

As a courtesy, the Broker of Record will receive a duplicate copy of the letter sent to their group(s). The letter will also be posted to the Document Center at TrustmarkSB.com/login for the employer, the Broker of Record and the broker’s managing general agent to view.

The Affordable Care Act and associated regulations require health insurance issuers and plan sponsors of self-funded group health plans to file and pay an annual PCORI fee.

Plan sponsors of self-funded health plan years ending in 2020 are required to pay the fee to the IRS and file Form 720 by July 31, 2021.

To learn more about the PCORI Fee, follow this link.

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Introducing Electronic Version of Form 1095-B for 2021 Tax Filing

Today, the following information will be emailed to employers that offer group health benefit plans administered by Star Marketing and Administration, Inc.

As an added benefit for employers, we are introducing an electronic version of Form 1095-B to assist employers with tax filing requirements for 2020. The form will be available to employers starting on Jan. 15, 2021, in the Document Center on our website. If you need to reference the data used to populate the forms, it will also be available in a CSV format in the Document Center. Continue reading

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IRS Releases New PCORI Fee

The IRS has announced that the Patient Centered Outcomes Research Institute (PCORI) Fee is $2.66 per average number of covered lives for plan years ending Oct. 1, 2020, through Sept. 30, 2021.

  • For plan years ending Oct. 1, 2020, through Dec. 31, 2020, fees are due July 31, 2021.
  • For plan years ending Jan. 1, 2021, through Sept. 30, 2021, fees are due July 31, 2022.

The previous fee was $2.54 per average number of covered lives for health benefit plans ending Oct. 1, 2019, through Sept. 30, 2020.

The institute, a nonprofit organization, uses the fee to fund research to compare different medical treatments and interventions to determine what treatments are most effective with the help of clinicians, purchasers, policymakers and patients. The institute will compile and distribute comparative clinical effectiveness research findings.

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New SBC Template for Plan Years Beginning Jan. 1, 2021

The U.S. Department of Labor has issued a new Summary of Benefits and Coverage (SBC) template, instruction, and related materials for use beginning on the first day of the first open enrollment period for any plan/policy years that begin on or after Jan. 1, 2021, with respect to coverage for plan/policy years beginning on or after that date.

You can access the new template here.
Click here to see a sample of a completed SBC.

Minimum Essential Coverage Disclosure
The release modifies the current SBC Template and Instructions to update the statement after the minimum essential coverage disclosure. The updated statement reads:

Minimum Essential Coverage generally includes plans, health insurance available through the Marketplace or other individual market policies, certain Medicare and Medicaid coverage, CHIP, TRICARE, and certain other coverage. If you are eligible for certain types of Minimum Essential Coverage, you may not be eligible for the premium tax credit.

This statement was updated because, as of Jan. 1, 2019, the tax payment required by an individual for not maintaining minimum essential coverage (unless he/she had a coverage exemption) was reduced to zero.

Template and Instructions
The SBC Template and Instructions have also been updated to include an additional option for issuers completing the minimum value disclosure on the SBC. Because the concept of minimum value is not relevant with respect to individual market coverage, the 2021 SBC Template adds “Not Applicable” as a response option for the minimum value disclosure, and reads:

Does this plan meet the minimum value standards? [Yes/No/Not Applicable].

The 2021 Instructions indicate that issuers of individual market coverage should answer “Not Applicable.”

Other Changes:

  • The update also adds the “Total Example Costs” for each of the three coverage examples to the template.
  • The release also updates the versions of the calculator, guides, and narratives in a number of ways. A complete list of updates to the Calculator, Guide, and Narratives is available here.

Click here for help with completing the SBC.

Click here to view related FAQs.

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Filed under Healthcare reform, SBC

Deadline Extended for Furnishing 2020 Form 1095

The IRS has extended the due date for furnishing 2020 Forms 1095-B and 1095-C to individuals from Feb. 1 (normally on Jan. 31, but it falls on a weekend) to March 2, 2021, and has provided some relief from penalties.

No extension to deadlines for filing with the IRS

  • This notice does not extend the due date of Feb. 28 (March 31 if filed electronically) for filing with the IRS 2020 Forms 1094-B, 1095-B, 1094-C or 1095-C.
  • The automatic extension remains available under the normal rules for filing the forms with the IRS for employers and other coverage providers who submit a Form 8809 on or before the due date.

Relief for failing to furnish a Form 1095-B to employees

The IRS will not assess a penalty against reporting entities for failing to furnish a Form 1095-B to responsible individuals (employees) when two conditions are met:

  1. The reporting entity must post a notice prominently on its website stating that responsible individuals may receive a copy of their 2020 Form 1095-B upon request, accompanied by an email address and a physical address to which a request may be sent, as well as a telephone number that responsible individuals can use to contact the reporting entity with any questions.
  2. The reporting entity must furnish a 2020 Form 1095-B to any responsible individual upon request within 30 days of the date the request is received.

Relief for incorrect or incomplete reporting

The IRS will not assess a penalty against reporting entities that report incorrect or incomplete information on the return or statement when these entities can show they made good-faith efforts to comply with the information-reporting requirements. In determining good faith, the IRS will take into account whether the reporting entity made reasonable efforts to prepare for reporting the required information to the IRS and furnishing it to employees and covered individuals, such as gathering and transmitting the necessary data to an agent to prepare the date for submission to the IRS or testing its ability to transmit information to the IRS. This is the last year the Treasury Department and IRS intend to provide this relief.

This information was released on Oct. 2, 2021, in IRS Notice 2020-76.

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Filed under 6055/6056 Reporting, Healthcare reform

2021 Cost-Sharing Limits; HDHP Out-of-Pocket Limits and Deductibles

A non-grandfathered group health plan’s in-network out-of-pocket maximum for essential health benefits (EHBs) for the 2021 plan year cannot exceed $8,550 for self-only coverage and $17,100 for other than self-only coverage. 1 This is an increase of approximately 4.9% percent from 2020. The in-network out-of-pocket maximum applies to all individuals, regardless of whether an individual has a self-only plan or other-than-single coverage.

Self-funded group health plans are not required to cover EHBs. But, if they do, they cannot impose lifetime or annual dollar limits on those benefits.

For high-deductible health plans (HDHPs) for the 2021 plan year, the out-of-pocket limit will be $7,000 for self-only coverage and $14,000 for other-than self-only coverage.2 The minimum deductible is not changing from 2020, remaining $1,400 for self-only coverage and $2,800 for other than self-only coverage.

1 Notice of Benefit and Payment Parameters for 2021, Final Rule from the U.S. Department of Health and Human Services, May 14, 2020

2 Rev. Proc. 2020-32 from the IRS, April 30, 2020

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Filed under Cost sharing, Healthcare reform, High-deductible health plan

Preventive Care Recommendations

The following U.S. Preventive Services Task Force (USPSTF) recommendations have been added to the preventive healthcare services that non-grandfathered health benefit plans must cover at 100% when provided by a network provider. Star Marketing & Administration, Inc., will implement the recommendations on the dates provided below.

  • Effective Sept. 1, 2020, in addition to risk reducing medications such as tamoxifen and raloxifene, the USPSTF recommends the prescription of aromatase inhibitors to women who are at increased risk for breast cancer and at low risk for adverse medication effects
  • Effective Dec. 1, 2020, anxiety screening for adult women and adolescent girls, including pregnant and postpartum women.
  • Effective Dec. 1, 2020, the recommendation for Hepatitis C screening for adults born between 1945 and 1965 and adults who are at high risk for infection, has been changed to screening for Hepatitis C in adolescents and adults aged 18 to 79.

The Affordable Care Act prohibits imposing member cost sharing, such as copayments, deductibles or coinsurance, when these services are provided by a network doctor or hospital. However, plans may impose cost sharing if the services are provided out of network.

For more on preventive care, follow this link.

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HHS Announces Changes in Implementing Anti-Discrimination Rule

The U.S. Department of Health and Human Services (HHS) has changed how it implements Section 1557 of the Affordable Care Act (ACA). The federal final rule applies to health plans, insurers, hospitals, doctors, and other medical providers that receive HHS funding.

Effective Aug. 18, 2020, changes to the 2016 version of the Section 1557 rule include:

  • Elimination of the requirement to issue anti-discrimination notices and taglines on all significant documents
  • Elimination of the requirement to designate a responsible employee and grievance procedures

Section 1557 prohibits discrimination on the basis of race, color, national origin, sex, age, or disability in certain health programs or activities.

The new rule eliminates a 2016 mandate that required covered entities to distribute non-discrimination notices and “taglines” translation notices in at least 15 languages in all “significant communications” to patients and customers. The regulations of the underlying statutes referred to in Section 1557 (Title VI, Section 504, Title IX, and the Age Act) have long mandated that covered entities provide a notice of nondiscrimination. This final rule maintains that requirement.

Moreover, it continues to require covered entities to provide taglines whenever such taglines are necessary to ensure meaningful access by LEP individuals to a covered program or activity. It removes only the requirement that all significant communications contain taglines.

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Filed under Healthcare reform, Non-Discrimination, Section 1557

Form 5500 Relief Deadline Approaching

The IRS issued Notice 2020-23 which addresses Form 5500, Annual Return/Report of Employee Benefit Plan filings due between April 1, 2020, through July 15, 2020. This relief does not include calendar year-end 2019 Form 5500 filings due July 31, 2020.

The relief is for Form 5500 filings that were either due to be filed originally or through an extension. The relief due date for filings has been extended to July 15, 2020. The extension automatically applies to Form 5500 filings for plan years that ended in September, October or November 2019 because the regular due dates for these filings would have been, respectively, April 30, June 1 (because May 31 was a Sunday), and June 30, 2020; these filings are now due July 15, 2020.

Taxpayers do not need to file official extension forms or send other documents requesting the relief. However, additional filing extensions beyond July 15 must be requested using the appropriate extension form by July 15, but the extension may not go beyond the original or regulatory extension date.

Notice 2020-23 states that Specified Time Sensitive Actions are covered and refers taxpayers to Rev. Proc. 2018-58, which explicitly addresses Form 5500.

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