Developments in Benefits - November, 2011
HHS Launches 2012 HIPAA Audit Program 
The HITECH Act requires HHS to provide for periodic audits to ensure covered entities and business associates are complying with the HIPAA Privacy and Security Rules and Breach Notification standards. To implement this mandate, the Department of Health and Human Services (HHS), Office of Civil Rights (OCR) began in November 2011, an initial 20 audits to establish and test audit protocols. Currently ongoing, the results from these initial audits will determine how the rest of the audits will be conducted. During 2012, the remaining audits, about 150 in all, will be conducted using the revised protocol materials. The pilot will be completed by the end of December 2012. - View the PDF
IRS Guidance on Tax-Free Coverage for Children under Age 27
The health care reform law requires group health plans that provide dependent coverage of children to continue to make the coverage available for an adult child until the child turns age 26. The extended coverage must be provided no later than plan years beginning on or after Sept. 23, 2010. - View the PDF
Health Care Reform: Delayed Compliance Date for Summary of Benefits and Coverage
The Patient Protection and Affordable Care Act (PPACA) adds to the list of necessary health plan disclosures by requiring plans and issuers to distribute a summary of benefits and coverage (SBC) to applicants and enrollees. The SBC is intended to be a relatively short document that provides important plan information in plain language so that health consumers can better understand their coverage options. This disclosure requirement applies to both grandfathered and non-grandfathered plans. - View the PDF
Health Care Reform: Simple Cafeteria Plans
The Patient Protection and Affordable Care Act (PPACA) amends Section 125 of the Internal Revenue Code (the Code) to allow certain small employers to establish “simple cafeteria plans” for plan years beginning after December 31, 2010.
Under the new law, these small employers can take advantage of a safe harbor from certain nondiscrimination requirements applicable to cafeteria plans as long as the following are met:
- Eligibility requirements - Participation requirements - Minimum contribution requirements
The safe harbor would also cover the nondiscrimination requirements applicable to certain benefits offered under a cafeteria plan including group term life insurance, coverage under a self insured group health plan, and benefits under a dependent care assistance program. - View the PDF
What is a medical child support order?
A medical child support order is a judgment, decree, or order (including an approval of a property settlement) that: Is made pursuant to State domestic relations law (including a community property law) or certain other State laws relating to medical child support (see Q1-8); and Provides for child (more)
