Insurance Plan Renewal and Benefit Reminders
Insurance Plan Renewal and Benefit Reminders
• Renegotiate insurance contracts, coverage and rates with providers.
• Communicate insurance plan options, changes, rates and coverage options to employees.
• Obtain needed insurance applications and waivers from employees.
• Establish new Cafeteria 125 plan, flexible spending accounts (medical and child care), if applicable and obtain waiver agreements from all non-participants.
CMS Online Disclosure
• If employer offers prescription drug benefits to any Medicare Part D eligible individual on the beginning date of their plan year, they are to complete the disclosure to CMS form for that plan year. This disclosure of creditable coverage status must be provided within 60 days after the beginning date of the plan year and must be made to CMS on an annual basis and upon any change that affects whether the drug plan is creditable. Provide online disclosure to CMS of creditable coverage status of your prescription drug plan at the following link: https://www.cms.gov/CreditableCoverage/45_CCDisclosureForm.asp
ERISA Summary Plan Descriptions (SPD) or SPD Wraps
• Employers are to provide employees with a SPD communicating plan rights and obligations to participants and beneficiaries within 90 days after becoming covered under the employer’s plan. Plan administrators of a new plan must distribute an SPD within 120 days after the plan is established. An updated SPD must be furnished to all covered participants every 5 years, and every 10 years for plans with no changes. Summary of Material Modifications (SMM) must be furnished automatically to participants when a plan is amended or “materially” modified.
Summary of Benefits & Coverage (SBC)
• Insurers and group health plans must provide a summary of benefits and coverage (SBC) document to each full time employee, and to family members of those enrolled in coverage in a standardized, consumer-friendly format, making it easier for participants to compare with other plans. The health insurance carrier prepares this for fully insured plans, and employers are responsible to prepare the SBC for self-funded policies.
5500 Report Due
Groups with 100+ employees are to submit a 5500 report to the IRS for all health and welfare plans. For plan years commencing on or after January 1, 2009, employers must file electronically using the EFAST2 processing system. These employee benefit plan forms are due by the last day of the seventh month after the plan year ends.
Using your HR Service, Inc. Compliance Basic service, an employee notifications report is emailed to you for distribution to your employee’s when you complete or update your Company Profile. The notification report meets the below health & welfare ERISA notification requirements.
Annual Notices :
Medicare Part D Notice (Certificate of Creditable (or Non-Creditable)) Drug Coverage
CHIP or premium assistance (if applicable in your state)
Wellness Program Disclosure (if providing wellness plan that is subject to HIPAA)
Women’s Health & Cancer Rights –Hospital Stay Rights for Childbirth
Notice of Non-Federal Governmental Plan Opt-Out (if applicable) – prior to first day of plan year.
Mental Health & Parity Act Notice of Availability of HIPAA Privacy Notice (every three years)
Grandfathered status notice (grandfathered plans only) – first day of plan year starting on or after 09/23/2010.
Other notices that maybe required include:
§ 125 Automatic/Evergreen Election Notice (applicable if automatic enrollment in place) For additional information go to: http://www.irs.gov/pub/irs-irbs/irb02-20.pdf
Summary Annual Report (SAR) (only if required to file form 5500) – within 9 months of end of plan year. Additional information and model language available at: http://www.dol.gov/ebsa/faqs/faq_auditwaiver.html
Sample notices for many of the qualifying events listed below can be found in the compliance basic’s center.
Qualifying Event Notices:
COBRA Election, Early Termination, Unavailability notice
FMLA rights notice (50+ employees)
HIPAA Notice of Breach or Unsecured PHI. – as soon as breach is determined and in no case later than 60 calendar days after discovery.
HIPAA Certificate of Creditable Coverage – upon termination of coverage
Qualified Medical Child Support Order Notice (QMCSO)
o Notification of receipt of order – promptly after receiving order
o Notification of determination – within a reasonable period
National Medical Support Notice (NMS)
Michelle’s Law – when plan is notifying participant of responsibility to certify student status.
Individual Notice of Preexisting Condition Notice (if applicable) – within 5 days of determination.
Summary of Material Modification (SMM) – within 210 days of end of plan year.
Summary of Material Reduction (SMR) – within 60 days of adoption
Wellness Program Disclosure (If subject to HIPAA) – any time plan materials are provided to participants.
30-day Advanced Notice of Rescission – first day of the first plan year starting on or after 09/23/2010
ERRP Notice – within reasonable time after the sponsor receives its first ERRP reimbursement (if employer receives reimbursement through Early Retirement Reimbursement Plan)
Employer Medical Benefit Event Specific Notices:
Prior to Enrollment in Employer Plan (open enrollment)
• General Notice of Preexisting Condition Exclusion (if applicable)
• Notice of HIPAA Special Enrollment Rights (including CHIP events)
• Certificate of Creditable (or Non-Creditable) Drug Coverage
• Dependent coverage extension and special enrollment – one time only notice. On first day of first year enrolled on or after 9/23/2010 or eligible to enroll.
• Lifetime limit elimination and special enrollment – one time only notice. On first day of first year enrolled on or after 9/23/2010 or eligible to enroll.
Upon Initial Enrollment in Employer Plan
• COBRA general notice/initial notice (provide within 90 days of becoming covered under employer health plan)
• Section 125 Pre-tax salary reduction agreement (If applicable)
• SPD (Summary Plan Description) – within 90 days of first becoming covered. Should include:
o Newborns and Mother’s Health Protection Act Disclosure NMHPA.
o Mini-Med Waiver Notice (for each year plan receives a waiver)
o PCP and OB/GYN choice notice (Non-grandfathered plans only)
• HIPAA Privacy Notice (if applicable)
• Women’s Health and Cancer Rights Act Notification
• Non-Federal Governmental Plan Opt-Out Notice (If applicable)
• § 125 Automatic/Evergreen Election Notice (if applicable)