EBIA Weekly Archives - CDHC - Questions

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  1. How does GINA limit requests for family medical history under a wellness program offered as part of a group health plan?
    From the April 15, 2010 EBIA Weekly
    QUESTION: We would like to offer a voluntary wellness program as part of our company’s self-insured group health plan. The program would request (but not require) employees to complete a health risk assessment questionnaire. Employees who complete ...
    [Jones v. Harris Assocs., 2010 WL 1189560 (U.S. 2010)]
  2. May our company's HRA reimburse qualifying medical care expenses incurred by HRA participants' domestic partners?
    From the December 17, 2009 EBIA Weekly
    QUESTION: Our company maintains a health reimbursement arrangement (HRA) for eligible employees. Several HRA participants have domestic partners. May we provide HRA coverage to these domestic partners? ANSWER: Yes, for domestic partners who are participants’ tax dependents. (For domestic ...
  3. May employees who have ceased to be HSA-eligible individuals still receive distributions from their HSAs?
    From the November 24, 2009 EBIA Weekly
    QUESTION: Some of our employees will no longer be HSA-eligible individuals as of January 1, because they’ll be switching from our company’s high-deductible health plan (HDHP) to its low-deductible health plan. May these ...
  4. Will employees be taxed on our company's new wellness incentive?
    From the November 12, 2009 EBIA Weekly
    QUESTION: In 2010, our company will be offering a series of “healthy lifestyle” information sessions as part of its wellness program. Each employee who attends every session in the series will pay $250 less in 2011 for his ...
  5. Do the MSP mandatory reporting rules require that HICNs or SSNs be provided to CMS?
    From the November 05, 2009 EBIA Weekly
    QUESTION: We’ve heard that the Medicare Secondary Payer mandatory reporting rules require that health insurance claim numbers or Social Security numbers be provided to CMS. In the past, it has been difficult to obtain those numbers for our ...
  6. In what order should reimbursements be paid when an employer offers both an HRA and a health FSA?
    From the September 24, 2009 EBIA Weekly
    QUESTION: Our company will set up an HRA and a health FSA on January 1 that will cover the same employees and pay the same types of medical care expenses. In what order should reimbursements be paid from these two ...
  7. Where can our health FSA participants use debit cards to pay for medical care expenses?
    From the August 20, 2009 EBIA Weekly
    QUESTION: Our company is thinking about implementing a debit card program for participants in our health FSA. I understand that IRS guidance restricts use of these cards to certain merchants. Where can our health FSA participants use debit cards to ...
  8. Can you explain how the Medicare Secondary Payer (MSP) mandatory reporting requirements apply to our health FSA and HRA?
    From the July 07, 2009 EBIA Weekly
    QUESTION: Our company is subject to the Medicare Secondary Payer (MSP) rules, including the MSP mandatory reporting requirements. We offer employees a health FSA and an HRA. Do the MSP reporting requirements apply to those plans? ANSWER: The MSP reporting ...
  9. Can our employees make pre-tax payroll contributions to their HSAs if we don't have a cafeteria plan?
    From the May 28, 2009 EBIA Weekly
    QUESTION: Our company offers a high-deductible health plan (HDHP), and many participants contribute to their own HSAs. Several have asked whether they could make pre-tax contributions to their HSAs so that they could get their income tax savings ...
  10. May we include as part of our HSA program a debit card for paying and reimbursing medical expenses?
    From the March 05, 2009 EBIA Weekly
    QUESTION: Our company contributes to its eligible employees’ HSAs, but we are concerned that many employees may be using their HSAs to pay for nonmedical expenses. Can we try to discourage our employees’ nonmedical spending by adding a ...

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