Volume 5, Number 7



Health Care Reform Updates
Summaries of Benefits and Coverage: Another Year of Eased Enforcement
E is for ERISA
The Departments of Labor, Treasury and Health and Human Services (Departments) extended transition relief with regard to Summaries of Benefits and Coverage (SBCs) for another year.
For 2015, the third such year, and until further notice, plan sponsors may continue to use the SBC and glossary templates published in April 2013 (with minor changes including deletion of a now obsolete reference to annual limits on essential health benefits). Click here to read more about the SBC transition relief.


ACA - Countdown to Compliance for Employers, Week 27: COBRA, Marketplace Coverage, Stability Periods and Cafeteria Plan Elections

Mintz Levin


Recent developments under ACA and COBRA, as well as existing rules governing mid-year election changes under cafeteria plans, have combined to make it challenging for certain terminating employees, and those employees who experience a reduction in hours, to continue health care coverage seamlessly. Read more of what employees in this category, and employers, need to know here.




Final Regulations on Orientation Periods Released



On June 20, the Federal regulatory agencies in charge of health care reform guidance (the Departments of Labor, Treasury, and Health and Human Services) released final regulations clarifying the relationship between a group health plan's eligibility criteria and the Affordable Care Act's 90-day limit on waiting periods.


Specifically, the final regulations (published in the June 25 Federal Register) address an employer's ability to require new employees to satisfy a "reasonable and bona fide employment-based orientation period" before starting a group health plan's waiting period. Read the full article here.



National Health Plan Identifiers Required by November

Spencer Fane Britt & Browne LLP


In the continuing saga of HIPAA compliance, most group health plans will have to obtain new health plan identifier numbers, or HPIDs, by November 5, 2014. The HPID must then be used in electronic transactions, including claim submissions, beginning November 7, 2016.


The HPID requirement applies to all group health plans that provide or pay for medical care. Read the full article here.

Enlighten Header_Wellness
ACA - Countdown to Compliance for Employers, Week 29: Wellness Programs, Smoking Cessation and

Mintz Levin


Health-contingent wellness programs require an individual to satisfy a standard related to a health factor to obtain a reward. However, nowhere do the final regulations address the role of electronic cigarettes, or "e-cigarettes."
Would an e-cigarette user be considered a smoker or nonsmoker? Do they qualify for wellness program rewards? Being an alternative standard to smoking, do e-cigarettes then qualify a smoker as a non-smoker?
These questions, along with the bigger question of whether e-cigarettes advance or hinder the cause of wellness, complicate matters. Read the full article here on what plan sponsors and employers have to consider for wellness programs with e-cigarettes in mind.

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Client Reminder: More information, regarding Health Care Reform and other benefit resources, is available on the HR360 website, available to BSG clients under the "Resources" menu of your HR Express website.
BSG subscribes to this service for your benefit. If you would like to learn more regarding this resource, please contact your account management team at BSG.
Additional Tools:
  • Pay or Play Toolkit
  • 2014 Health Care Reform Checklist
  • Performance Review Builder





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Enlighten is published by The Benefit Services Group, Inc., (BSG®) and is provided free of charge to select BSG client representatives and associates.


By providing links to other sites, BSG does not guarantee, approve or endorse the information or products available at these sites, nor does a link indicate any association with or endorsement by the linked site to BSG.


The preceding is not intended to be and is not offered as legal advice. We are prohibited from the practice of law. Compliance is the responsibility of the employer or Plan sponsor and affected employees who should seek their own legal counsel regarding questions about information presented in this newsletter.


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