Benefit Allocation Systems, Inc. and its MyEnroll.com uses email addresses to communicate with plan participants. In order to be certain that the email address an employer provides MyEnroll.com, or an email address that an administrator and/or employee enters into MyEnroll.com is truly associated with the corresponding employee, BAS requires that the employee verify the email address. This email verification must take place before MyEnroll.com will use the address for employee communications.
A recent hacking breach impacted more than 50 million users of the daily deals website, LivingSocial. Names, email addresses, birthdates and encrypted passwords may have been improperly accessed by the hackers. Personal financial information was not implicated since LivingSocial stores such information separately from other personal data.
Beginning this fall, individuals will be able to enroll in the new health insurance Exchanges for coverage effective January 1, 2014. To enroll in coverage, individuals will have to complete an application process.
A recent court settlement in Alabama stresses the importance of proper COBRA notice procedures and documentation.
Q.- An employee participates in our health care FSA. The employee’s child is getting braces in January 2014. The orthodontist is starting a treatment plan in the fall this year (2013). If the employee pre-pays for the orthodontia, she will get a discount from the orthodontist. She asked if the pre-payment can be reimbursed from her 2013 health FSA, even if the braces are not placed on her child’s teeth until 2014.
A.- Probably yes, to the extent there are funds in the 2013 health FSA. A health FSA may permit reimbursement of advanced orthodontia payments. Generally, an expense under an FSA must be incurred during the period of coverage (including any grace period). The general rule is that an FSA may not make advance reimbursement of future or projected expenses, and an FSA cannot reimburse an expense that has been paid but not incurred. However, there are special rules that apply to orthodontia expenses. IRS rules provide that a health FSA may reimburse advance payment for orthodontia services, so long as the employee has actually made the payments in advance to receive the services. Under these IRS special rules, the orthodontia services are deemed incurred when the employee makes the advance payment, instead of when the child sits for the orthodontia services.
“Reputation management” has been a quickly increasing business plan for new companies. Some of these new companies claim to monitor and manage consumers’ online reputation by removing or modifying negative or unwanted information obtained through web search results.
Unfortunately, one reputation management company, Reputation.com, encountered a network attack causing their clients’ personal information to be inappropriately accessed. The breach involved access to names, email addresses, physical addresses, and in some cases phone numbers, date of birth and job information. The company notified affected individuals and offered a year of free credit monitoring.
The Department of Health and Human Services’ Centers for Medicare and Medicaid Services (CMS) issued a notice recognizing that agents and brokers will play an important role in communicating coverage offered under the federally-mandated health insurance Exchanges. Specifically, agents and brokers, including web brokers, will be called on to educate consumers about Exchanges and insurance affordability programs, to help consumers receive eligibility determinations, compare plans and enroll in coverage. CMS anticipates that brokers and agents will be integral to helping qualified employers and employees enroll in coverage offered through the Small Business Health Options Programs (SHOP).
The CMS guidance acknowledges that the government will work with agents and brokers, and also provides an overview of their expected role. CMS anticipates that agents and brokers will assist consumers in completing the Exchange eligibility application and will provide advice for comparing and selecting qualified health plans offered through the Exchange. Agent and broker assistance will take one of two approaches: (a) an issuer-based pathway, through which an agent or broker users an issuer’s website to help the consumer, or (b) a Marketplace pathway through which an agent or broker uses the Exchange’s website to help the consumer. Either approach will provide the agent/broker the opportunity to provide identifying information to the issuer for the issuer’s payment to the agent/broker for each enrollment transaction. Either approach will also allow the agent/broker the right to assist both employers and employees with initial enrollment and mid-year coverage changes.
Yahoo, a leading company that is frequently in the news for its human resources decisions, has increased the amount of paid leave available to both mothers and fathers upon the birth/adoption of a child.
Q.- An employee is going on maternity leave. May she continue to submit expenses for reimbursement from her FSAs while she is on leave?
Name.com, a domain registrar, announced to its users a security breach through which unauthorized hackers may have accessed user names, email addresses, encrypted passwords and encrypted credit card information.
The Departments of Labor, Treasury and Health and Human Services issued guidance on the Summary of Benefits and Coverage (SBC) that must be issued by group health plans and health insurance issuers with respect to coverage beginning on or after January 1, 2014 and before January 1, 2015. The SBC is a new documentation requirement under health care reform to allow plan participants to better understand the coverage they have and give them the opportunity to compare their coverage against different plan options.
HIPAA requires health plans to have a standard health plan identification number (HPID), to facilitate the transfer of information among covered entities. Presently, health plans use many different forms of identification numbers when referring to patient and plan information. The HPID is a 10 digit number that will be universal across entities which is intended to make plan communication easier.
Q.- My employer offers a high deductible health plan with a health savings account. May I participate in the HSA/HDHP and also participate in an FSA?
A United States Department of Labor website has been infecting malware on visitors' computers through drive-by download attacks.
Beginning in 2014, individuals and employees of small businesses will have the opportunity to purchase health insurance through a state-based Health Insurance Marketplace known as the Exchange. Open Enrollment for the Exchanges begins October 1, 2013. As discussed in previous articles, employers must provide employees information about the coverage options available through the Exchange. Yesterday, the Department of Labor issued model language to be used for the Exchange notice.
More and more employers are implementing wellness programs in an attempt to contain health care costs. CVS Caremark has recently made headlines for requiring all of its employees to undergo a health screening or pay an additional $50 per month for health coverage.
Q.- We have an employee who is enrolled in our HMO. When she terminates employment, she is moving out of state. We also offer a PPO plan which will be more useful to her. Should we offer her the PPO plan for her COBRA election or stick with the HMO?
Employers can manage dependent eligibility through MyEnroll.com.
Oregon Health & Science University has reported a breach of personal health information for 4,000 patients. The breach occurred when an unencrypted laptop was stolen from a surgeon’s rental property when he was on vacation in Hawaii.
The patient information was located in emails stored on the laptop, and contained daily surgery schedules. The information included name, gender, date of birth, medical record number, type of surgery and surgery date.
Proposed regulations issued under the Affordable Care Act would eliminate the requirement to provide a HIPAA Certificate of Creditable Coverage when a participant terminates coverage under a group health plan. A group health plan or health insurance issuer provides a certificate of creditable coverage to a participant to document the duration of a participant’s health coverage. Presently, a certificate must be issued when coverage is lost under a group health plan, when an individual is entitled to elect COBRA continuation coverage, and when COBRA coverage ends. The certificate shows the individual’s most recent period of creditable health coverage.
Before health care reform, plans could impose pre-existing condition limitations on new enrollees. Prior creditable coverage could off-set a pre-existing condition limitation. Participants documented prior creditable coverage by producing a HIPAA certificate.
A penalty awarded in a recent court case provides one more reason for employers to implement proper COBRA administrative processes.