Special HSA Contribution Limit for Spouses

Question:  What is the HSA contribution limit for each spouse where both spouses are HSA eligible? Short Answer: Where at least one spouse is enrolled in family HDHP coverage, the combined HSA contributions for both spouses cannot exceed the annual family limit. General Rule: HSA Eligibility The general rule is that an individual must meet […]

How to Cultivate an Environment for Innovation

Innovation is important to every field but can be a vague and aspirational goal. Yet, it is crucial to foster this behavior for success in the fast-paced world of digital change. For example, consider a bulk marine terminal that must move product across a fixed footprint to remain a viable transportation solution.  Virtually, every industry must […]

2020 Health FSA Limit Increased to $2,750

Today the IRS confirmed in Revenue Procedure 2019-44 that for plan years beginning on or after January 1, 2020, the health FSA salary reduction contribution limit will increase to $2,750. This represents a $50 increase from the current $2,700 salary reduction contribution limit for plan years beginning on or after January 1, 2019. As a reminder, employer contributions […]

Early Termination of COBRA Upon Enrollment in Other Group Health Plan or Medicare

Question:  How does enrollment in another employer-sponsored group health plan or Medicare affect a qualified beneficiary’s COBRA rights? Compliance Team Response:   Short Answer: COBRA generally terminates early where the qualified beneficiary first becomes covered under another group health plan or Medicare after COBRA is elected. General Rule: COBRA Maximum Coverage Period Absent an early […]

Medicare Secondary Payer Employer Size Requirements

Question:  At what size are employers subject to the Medicare Secondary Payer rules? Short Answer: The Medicare Secondary Payer rules generally apply at 20 employees for Medicare entitlement based on age, and 100 employees for Medicare entitlement based on disability. Medicare Secondary Payer Rules: General Rule The Medicare Secondary Payer (MSP) rules prohibit employer-sponsored group […]

COBRA Small Employer Exception

Question:  When does the COBRA small employer exception apply? Short Answer:  The small employer exception from the federal COBRA requirements applies if the employer had fewer than 20 employees on at least 50% of its typical business days in the preceding calendar year. Small Employer Exception: General Rule The federal COBRA continuation coverage rules do […]

Group-Term Life Insurance §79 Nondiscrimination Rules

Question:  Are there nondiscrimination rules that apply to group-term life insurance benefits? Short Answer: Yes, Section 79 imposes nondiscrimination rules that generally require employers to offer non-key employees the same level of coverage as offered to key employees. Section 79 Nondiscrimination: General Rule The nondiscrimination rules that apply to group-term life insurance plans generally require […]

Potential ACA Employer Mandate Penalties for Late Offer of Coverage to New Full-Time Hire

Question:  What are the potential ACA employer mandate penalties for failure to timely offer coverage to a new full-time hire (including a full-time temp or intern)? Compliance Team Response:   Short Answer: The “B Penalty” ($312.50/month in 2019, $321.67/month in 2020) may apply for the failure to timely offer coverage to a new full-time hire. […]