A.- No.  Your employer will likely not be subject to the Federal COBRA rules for 2012.  COBRA applies to individuals who lose their group health plan coverage as a result of a qualifying event.  Employers with 20 or more employees on a typical business day in the PRIOR plan year are subject to COBRA.  Since your employer did not exist in the prior plan year, it should not be subject to Federal COBRA until 2013.

1.  Call Center Verification.  The BAS call center fields hundreds of questions each day from participating employees.  Before our call center professionals will provide information to an employee, the caller is asked to identify two pieces of personal information, such as home address (including zip code), date of birth, last 4 digits of social security number, or BAS reference or ID number.  The call center can also process self-verification; whereby the caller can enter verification information over the telephone, before access to a client service representative.  When the caller reaches client services, the caller has to verify only one piece of personal information.

2.  Keep Passwords Secure.  As discussed in previous newsletters, a unique User ID and Password is required to access MyEnroll.com.  Access to MyEnroll.com is denied after 5 unsuccessful login attempts.  BAS employees are instructed not to write down passwords and to use sufficiently complex passwords that cannot be extrapolated.

3.  Lock your Computer.  BAS’ internal computer screens automatically lock after a limited period of no access.  The automatic locking feature is a necessary part of business today.  All BAS employees are instructed to manually lock their computers if stepping away from their desks, without having to wait for the automatic lock.

4.  Shred Paper.  BAS maintains easily accessible shredders for employee use.  If documents are scanned into our secure system, employees are advised to shred papers with identifying information.

5.  Monitor Documents Left on Printer.  The BAS privacy official and her delegate visit open printers throughout the day to monitor documents.  If a document with personal information is inadvertently left on a printer, the document is confiscated and either returned to the generating employee or shredded.

BAS takes great interest in maintaining the privacy of personal information and continually implementing best practices for data security.  Companies should review their privacy best practices to make sure they are in keeping with a changing workforce.

Here’s how it works: Based on the employees’ enrollment data in MyEnroll.com, each premium-payment-due-period (usually monthly but it can be more frequent depending on each carrier’s specific requirements), MyEnroll consolidates the employees’ current and retroactive adjustments (for adds, changes and terminations, if any), benefit elections, premium, coverage date, and benefit volumes/level into one PDF. Thus, all current debits and retroactivity credits and debits flow neatly and organized on to the Self-Billing reports, in accordance with the insurance carriers’ specifications. Thereafter, MyEnroll stores a copy of the Self-Billing PDFs for historical purposes and delivers a copy to the employer’s contact responsible for paying its carriers.

The real benefit of these reports is twofold: (1) accuracy and (2) ease of preparation. With regard to accuracy, the premium and benefit calculations are all driven from a single rates and calculations table in MyEnroll, which is the same group of tables used for all premium and benefit calculations throughout MyEnroll presentation screens and reports (e.g., employee benefit statements, enrollment wizard pages, coverage reports, etc.). The single source for rates, premiums and benefit levels assures that the calculations for current premiums and retroactive debits and credits occur the same way, every time. With respect to ease of preparation, BAS’ Self-Billing reports eliminates employers having to create monthly insurance carrier transmittal reports and to maintain spreadsheets with all of the current month’s and retro periods’ adjustments.  Within seconds MyEnroll generates these Self-Billing reports on schedule and without fail. In short, MyEnroll does all the work and the employer only needs to open the email delivering the Self-Billing reports, double-check their accuracy and pay them to the carriers.

BAS’ Self-Billing reporting services are priced inexpensively at $0.30 per employee per month, which includes the record keeping, PDF generation and emailing, and PDF archiving. To learn more about BAS’ time saving Self-Billing service, contact BAS at 1.800.945.5513 Menu Option #3 (Sales), your BAS account manager, or email us at Sales@BASusa.com.

The new guidance released last week provides that SBCs may be distributed electronically to participants and beneficiaries in connection with their online enrollment or online renewal of coverage under the plan. SBCs also may be provided electronically to participants and beneficiaries who request an SBC online. In either case, the individual must have the option to receive a paper copy upon request.

The rules require that an SBC be distributed “upon application” and on the “first day of coverage.”  New guidance provides that for this purpose, a plan must provide the SBC as soon as practicable, but no later than 7 business days after receiving a substantially complete application for health insurance.  If a plan sponsor is negotiating coverage terms after an application has been filed and the information in the SBC changes as a result, an updated SBC is not required to be distributed, unless requested, until the first day of coverage.

The SBC must include certain examples of coverage under the plan.  New guidance confirms that the government is developing a calculator that plans and issuers can use as a safe harbor for the first year to complete the coverage examples in a streamlined fashion.

Comments to the SBC rules questioned how an SBC would be produced when an employer’s plan included multiple coverages across multiple providers.  Specifically, issuers wanted to know their obligations to provide an SBC with respect to benefits they do not insure.  The guidance states that unless it contracts otherwise, an issuer has no obligation to provide coverage information for benefits that it does not insure.  However, health plan administrators are responsible for providing complete SBCs for their plans.  The administrator has the option of combining information from various insurers into one SBC.  During the first year of applicability, multiple SBCs will be permitted.  The plan administrator should take steps to indicate that the plan provides coverage using multiple different insurers and provide contact information.

Revised SBC examples were also released to correct errors in previously issued documents.

BAS can provide assistance coordinating SBCs from multiple insurers and distributing SBCs electronically.  For more information, please contact sales@BASusa.com.

An HSA is a tax-exempt trust or custodial account set up with a qualified HSA trustee to pay or reimburse certain qualified medical expenses.  An HSA can only be established for the benefit of an eligible individual who is covered under a high deductible health plan and has no other health coverage.  An employee with an HSA may not be enrolled in Medicare and may not be claimed as a dependent on anyone else’s tax return.

Contributions made to an HSA are not taxable income to the participant.  Contributions remain in the HSA account from year to year until they are used, and earnings on the HSA amounts accumulate tax free.  Distributions from the HSA may also be tax free if they are used to pay qualified medical expenses.  An HSA is portable and is not tied to a single employer.

An HDHP, which is required for HSA participation, has a higher annual deductible than other plans, but does limit the maximum out of pocket amount that the participant must pay for covered expenses.

The new limits for HDHPs and HSAs, effective January 1, 2013, are as follows:

• The maximum annual contribution to a self-only HSA for HDHP coverage increases from $3,100 to $3,250.
• The maximum annual contribution to a family HSA for HDHP coverage increases from $6,250 to $6,450.
• The age 55 and over annual catch up contribution remains at a $1,000.
• The minimum self-only HDHP deductible increases from $1,200 to $1,250.
• The minimum family HDHP deductible increase from $2,400 to $2,500.
• The maximum self-only HDHP out-of-pocket expense amount increases from $6,050 to $6,250.
• The maximum family HDHP out-of-pocket expense amount increases from $12,100 to $12,500.

An employer that offers an HSA and HDHP should make sure that plans and systems account for the new limits.  Employers with HSAs should be mindful that if a health flexible spending account plan is offered, an employee who has an account balance remaining at the end of the plan year that goes into a grace period, the remaining FSA balance may preclude participation in an HDHP/HSA arrangement as it will be considered “other coverage” thereby removing the participant from HDHP/HSA eligibility.

2.     COBRA Participants Payment Detail – Detailed break-out of how the participants’ payments were applied by coverage.

3.     COBRA Participation Activity Summary – Current status of all COBRA participants.

4.     Remittance Check – Image of the Remittance check that was mailed.

These reports are also available on MyEnroll.com 24×7 through the COBRA Administration module.

Users of MyEnroll.com must be vigilant about online security.  The MyEnroll user ID and password is designed to protect users by confirming their identities when accessing MyEnroll.com.

Passwords should be kept confidential and not shared with others, even other administrators in the same organization.  New administrators can always be set up in MyEnroll.com by clicking on the Request User ID and/or Password link located on the MyEnroll.com home page.  Follow the easy instructions for Adding a New Administrator.  The Administrator Account Access Request Form obtained through MyEnroll.com should be printed, completed, and returned to BAS for processing.

Please follow these helpful tips for keeping user IDs and passwords secure:

• Do not write down your password or post it near your computer.
• Change your password on a regular basis.
• If you suspect that someone has had access to your password, change it.
• Do tell anyone your password.
• Use different passwords for different secure access.
• Do not choose a password that can be easily guessed (such as your first or last name, or a string of numbers).

Passwords to access MyEnroll.com must be between 8 and 14 characters long, with both upper and lowercase letters and symbols.  To change your password, log on to MyEnroll.com and Click on the Manage Your Access link located in the Menu options under the Tools section.

The Centers for Medicare and Medicaid Services (CMS) provides guidelines on the standard Medicare Part D benefit.  CMS recently updated those parameters for 2013.  Employers with prescription drug plans will have to review those plans to determine if their coverage remains creditable.  Notice must be provided to Medicare Part D individuals by October 15, 2012.

For 2013 the following parameters will be used to determine actuarial value.  Each value is increased from the 2012 values.

• Deductible: $325;

• Initial coverage limit: $2,970;

• Out-of-pocket threshold: $4,750;

• Total covered Part D spending at the out-of-pocket expense for beneficiaries not eligible for the coverage gap discount: $6,733.75;

• Estimated total covered Part D spending at the out-of-pocket expense for beneficiaries are eligible for the coverage gap discount: $6,954.52; and

• Minimum co-pays under the catastrophic coverage benefit: $2.65 for generic/preferred multi-source drugs, and $6.60 for all other drugs.