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high deductible health plan

It’s Back to Basics for Employee Benefits Priorities

By Lisa Loesel on Sep 3, 2020
Posted In Employee Benefits, Health and Welfare Plans, Retirement Plans

Prior to the pandemic, ultra-low unemployment at roughly 3.3% put a spotlight on ‘lifestyle benefits’ for employees such as gym memberships and pet sitting. When the COVID-19 crisis hit, the focus immediately shifted for many plan sponsors.

Some employers are now offering high-deductible health plans (HDHPs) paired with health savings accounts (HSAs). Scaling back on company matches to 401(k) plans and contributions to profit sharing accounts are two other areas where employers are trying to save money, said Lisa Loesel, an employee benefits partner at McDermott.

“Depending on what kind of plan they have and the terms set forth for them, we have seen plan sponsors delay the timing of their contributions, change the amount, move from a fixed to a discretionary amount or even cut their contributions indefinitely,” Loesel said in a recent article for PLANSPONSOR Magazine.

Among sponsors offering a pension plan, more are de-risking their plans. “The market happens to be favorable for doing this right now,” she says.

IRS Issues Relaxed Cafeteria Plan Rules

By Jacob Mattinson and Judith Wethall on May 26, 2020
Posted In Health and Welfare Plans

To help cafeteria plan participants address challenges arising from the COVID-19 crisis, the Internal Revenue Service recently issued guidance allowing employers to make a number of participant-friendly changes under their cafeteria plans. While employer adoption of these more flexible rules is voluntary, plan sponsors should work with third-party administrators, insurance providers and legal advisors to ensure that the new provisions are properly adopted, documented and communicated.

Access the full article.

IRS Announces 2021 Limits for Health Savings Accounts and High-Deductible Health Plans

By Jacob Mattinson and Judith Wethall on May 21, 2020
Posted In Health and Welfare Plans

The Internal Revenue Service (IRS) recently announced cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2021. Some of the dollar limits currently in effect for 2020 will change for 2021.

Access a table comparing the applicable dollar limits.

HSA Eligibility Not Disrupted by COVID-19 (Novel Coronavirus) Testing and Treatment

By Erin Turley, Jacob Mattinson and Judith Wethall on Mar 12, 2020
Posted In Employee Benefits, Employment, Health and Welfare Plans

A new IRS notice will allow individuals to receive testing and care for COVID-19 without jeopardizing their ability to contribute to a health savings account (HSA). The IRS issued the notice due to the public health threat posed by COVID-19, and the stated need to eliminate potential administrative and financial barriers to testing for and treatment of COVID-19.

Access the full article.

7 Tips to Avoid Compliance Missteps During Open Enrollment

By Jacob Mattinson and Megan Mardy on Nov 6, 2018
Posted In Employee Benefits, Health and Welfare Plans, Privacy and Data Security

One of the busiest times of year for an employee benefits professional is open enrollment. It is a crucial and yet stressful time of year that typically results in numerous employee questions and complaints and is a time of year with high potential for both employer and employee mistakes. Despite the stress and potential for problems, open enrollment provides an opportunity for a company to set itself up for success for the following year.

The Employee Retirement Income Security Act (ERISA) does not require an annual opportunity for employees to change benefit plan elections. However, because of compliance issues that can spring from not offering a regular enrollment period, most companies choose to offer an “open enrollment” period, usually taking place in mid- to late fall for calendar-year health and welfare benefit plans.

Employee attention to employer communications during this period is often high, and attention to detail in participant communications behooves an employer during this period. Well-written and timely notices may be relied upon to satisfy many compliance obligations. Inaccurate or incomplete open enrollment materials, however, can create employee confusion and result in legal liability under the complex network of federal laws governing employer-sponsored benefit programs.

Read the full article here for a sampling of key issues to consider to help you avoid compliance missteps during this year’s open enrollment period.

Originally published in BenefitsPRO.com, October 2018.

IRS Announces HSA Contribution Limit Increase for 2018

By Jacob Mattinson, Judith Wethall and Megan Mardy on May 1, 2018
Posted In Employee Benefits, Health and Welfare Plans

On April 26, 2018, the Internal Revenue Service (IRS) increased the 2018 maximum deductible Health Savings Account (HSA) contribution for taxpayers with family coverage under a High Deductible Health Plan (HDHP) to $6,900.

The $6,900 contribution limit for 2018 was originally published in Revenue Procedure 2017-37, but was reduced earlier this year by $50 to $6,850 in Revenue Procedure 2018-18 due to changes in the inflation indexing measure under the Tax Cuts and Jobs Act. The IRS later increased the limit back to the originally announced amount of $6,900. This relief is published in Revenue Procedure 2018-27 and appears to be the result of pushback from employers, many of whom would face significant administrative costs due to implementing the mid-year change, and governing law requiring the annual HSA limits to be published by no later than June 1 of the preceding calendar year.

Under the guidance, an individual who received a distribution from an HSA in 2018 of an excess contribution based on the previous $50 reduction may repay the distribution to the HSA by April 15, 2019. The repaid amount would not be included in the individual’s gross income or subject to additional taxation. Alternatively, such individual may take no action and treat the $50 HSA distribution as an excess contribution that was timely returned and thus not subject to income inclusion or additional taxation.

Employers who previously lowered their plan’s contribution limit for HSAs to $6,850 should consider how to address the increased limit and whether any changes or employee communications are necessary.

IRS Announces Limits for Health Savings Accounts and High-Deductible Health Plans for 2017

By Jacob Mattinson on May 3, 2016
Posted In Health and Welfare Plans

Recently the Internal Revenue Service (IRS) announced (see Revenue Procedure 2016-28) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2017. Although one of the dollar limits currently in effect for 2016 will change, the majority of the limits will remain unchanged for 2017, with some of the limits remaining unchanged since 2015. The table below compares the applicable dollar limits for HSAs and HDHPs for 2016 and 2017.

HEALTH AND WELFARE PLAN LIMITS 2017 2016 HDHP – Maximum annual out-of-pocket limit (excluding premiums): Self-only coverage $6,550 $6,550 Family coverage $13,100 $13,100 HDHP – Minimum annual deductible: Self-only coverage $1,300 $1,300 Family coverage $2,600 $2,600 HSA – Annual contribution limit: Self-only coverage $3,400 $3,350 Family coverage $6,750 $6,750 Catch-up contributions (age 55 or older) $1,000 $1,000

Plan sponsors should update payroll and plan administration systems for the 2017 cost-of-living adjustments and should incorporate the new limits in relevant participant communications, like open enrollment and communication materials, plan documents and summary plan descriptions.

For further information about applying the new HSA and HDHP plan limits for 2017, contact your regular McDermott lawyer or one of the contacts listed below.

IRS Releases 2015 Amounts for HSAs, HDHPs

By McDermott Will & Emery on Apr 24, 2014
Posted In Health and Welfare Plans

On April 23, 2014, the U.S. Treasury Department and Internal Revenue Service (IRS) released Revenue Procedure 2014-30, which lists the 2015 indexed amounts, adjusted for inflation, for health savings accounts and high-deductible health plans (HDHPs). The following table lists the current 2014 amounts and the new 2015 amounts:

Calendar Year 2014

Calendar Year 2015

Self-only

Family

Self-only

Family

Annual Contribution Limit

$3,300

$6,550

$3,350

$6,650

HDHP Minimum Deductible

$1,250

$2,500

$1,300

$2,600

HDHP Out-of-Pocket Limit
(includes deductibles, co-payments and other amounts but not premiums)

$6,350

$12,700

$6,450

$12,900

The Revenue Procedure is effective for calendar year 2015.

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