Agents

IRS Notice 2015-87 provides guidance on the impact of the Affordable Care Act (ACA) on consumer-directed health plans, effective for plan years beginning on or after 1 January 2017.

The IRS has released the 2017 cost-of-living amounts (COLAs) for HSA-qualifying high-deductible health plans. Deductible and out-of-pocket amounts, which apply to in-network benefits only, have not changed for 2017.

The Federally Facilitated Marketplaces (FFMs) have begun sending notices informing employers that employees have enrolled in an FFM and were determined to be eligible for premium subsidies.

On April 6, 2016, the Centers for Medicare & Medicaid Services (CMS) published the final template for the Summary of Benefits and Coverage (SBC) and Uniform Glossary. Health plans must use the new SBC template and Uniform Glossary on the first day of the first open enrollment period that begins on or after April 1, 2017, with respect to coverage for plan years beginning on or after that date.

The Health and Human Services Office of Civil Rights (OCR) has officially begun its Phase 2 Audit Program under HIPAA. Phase 2 audits could involve desk audits or on-site assessments and will be completed by the end of 2016. Covered entities should take steps now to prepare for these audits and to mitigate potential risks.