Comparative Solutions - Blog by Kendra

ARPA Benefits Are Here!

Fri, 30 Apr 2021 16:03:10 -0700

On March 11, President Biden signed the American Rescue Plan Act (ARPA), which features a number of exciting healthcare provisions, including COBRA subsidies, an extension of the new Special Enrollment Period that began in March and an increase in Dependent Care FSA maximums. While individual states are still determining the best way to put this new healthcare legislation into action, here is what we know so far.

COBRA Premium Subsidies

ARPA provides full COBRA premium subsidies for eligible individuals from April 1, 2021 through September 30, 2021. This means that as long as qualified individuals are enrolled in COBRA by April 1 or elect COBRA coverage within the window for subsidies, the subsidies will cover 100% of the cost of COBRA. To qualify for these subsidies, individuals must have experienced either (1) an involuntary termination of work, such as being fired or let go, or (2) a reduction in work hours, and thee events do not have to be COVID-19 related To those who voluntarily end their employment or experience other COBRA-qualifying events do not qualify for the COBRA subsidies.

ARPA SEP Extended

ARPA also created an extension of the Special Enrollment Period that went into effect in February 2021. The new Special Enrollment Period will extend to August 15, 2021, allowing more individuals to enroll in Marketplace coverage and allowing those already enrolled to change plans due to increased tax credits that ARPA has made available.

ARPA has also created another Special Enrollment Period specifically for Assistance Eligible Individuals (AEIs). These are qualified beneficiaries who are eligible for COBRA coverage due to an involuntary termination of work or a reduction in work hours. (These events are not required to be caused by COVID-19 in order for an individual to qualify.) This new Special Enrollment Period began April 1 and will run until 60 days after the qualified individual receives written notice that they are eligible to elect COBRA coverage.

Dependent Care Increase

ARPA has significantly increased the Child and Dependent Care Tax Credit (CDCTC) and the amount households can exclude from taxable income for Dependent Care Assistance Programs (DCAP). The new relief act more than doubles these amounts. The maximum contributions for DCAPs have increased to $10,500 for married couples filing jointly or $5250 for individuals or married couples filing separately.

FAQs Regarding ARPA of 2021

Are all COBRA-standard Qualifying Events (QEs) eligible for the ARPA Subsidy?
Does the QE have to be COVID-related to qualify for the ARPA Subsidy?
Are the dependents of an AEI also eligible for the ARPA Subsidy?

For your convenience, we have included a list of these and other common ARPA COBRA subsidy FAQs on our blog.

Let's Get the Ball Rolling!

The act will also provide credits of up to 50% of childcare expenses to a maximum of $8,000 for households with one child and $16,000 for households with two or more children. These increased benefits will be in effect from January 1, 2021 to December 31, 2021.

All of the new changes that ARPA has put in place make this the perfect time to take advantage of the extended SEP or set up COBRA and FSA accounts with us if you don’t have them yet. Comparative Solutions is a one-stop shop. From verifying eligibility and handling reimbursement claims to providing notices and keeping records, we will manage the details and keep everyone in compliance. We handle benefits administration so that employees can make the most of these new provisions and employers can focus on managing their businesses. In addition to COBRA and FSA administration, we also provide HRA, HSA, and Commuter benefits. Whatever you're looking for, we've got you covered. Contact Comparative Solutions today to get the ball rolling!

HRA Accounts: Creatively Caring For Your People

Thu, 11 Mar 2021 15:14:40 -0800

Employers searching for ways to provide affordable benefits coverage for employees may find that an HRA, ICHRA, or QSEHRA account is the perfect solution.

We’ve lived through a year filled with economic downturn, unexpected illness and death, unpredictable healthcare costs, and social unrest and upheaval. By October 2020, more than 60 million people filed for unemployment, losing both jobs and healthcare coverage. As the nation begins to rally and recover, people are looking for ways to save money on necessary health coverage as they get back on their feet, and employers are searching for sufficient, affordable options to offer their teams while keeping their own doors open.

The Special Enrollment Period (SEP), currently underway from February 15 – May 15, 2021, is the perfect opportunity for employers to consider non-traditional options for employee benefits. With affordability and flexibility as top priorities for everyone, HRA, ICHRA and QSEHRA benefit accounts will likely see a rise in enrollment rates. They are flexible account options that can be structured meet the needs of a variety of people in different circumstances. Employers searching for ways to provide affordable benefits coverage for employees may find that an HRA, ICHRA, or QSEHRA account is the perfect solution.

Traditional HRAs

You may already be familiar with HRA accounts, as they have been around for a little while and are growing in popularity. Health Reimbursement Arrangements (HRAs) are a type of healthcare benefit account that is owned and funded exclusively by employers. Employees do not pay into an HRA, but they can use the funds in this account to cover eligible medical expenses for themselves and their dependents.

These benefit accounts afford employers more flexibility in designing the benefit plans they offer employees. HRAs are not health insurance and cannot be used to pay insurance premiums, but because employers can structure them in ways that can be most beneficial for their employees, they are often pair these accounts with an employer’s health insurance plan, especially High Deductible Health Plans (HDHPs), to help employees pay for medical costs not covered by their health plans.

These include:

Coinsurance and deductible expenses

Dental and vision care
Visits to specialists or alternative medical practitioners, such as chiropractors or physical therapists
Medications, whether prescription drugs or over the counter items.

Traditional HRA accounts can be set up so that employees can use them one of two ways. They can either:

draw from their HRA account funds and use those entirely before paying any out-of-pocket costs (or using HSA/FSA funds), or
pay for their own medical expenses, either out of pocket or with HSA/FSA funds, until they have reached a specific threshold determined by the employer. After this threshold has been met, the HRA funds can be used until they run out.

What is an ICHRA?

ICHRA stands for Individual Coverage HRA (health reimbursement arrangement). An Individual Coverage HRA is different than a traditional HRA in that it is can be coupled with a traditional health plan or take the place of one. It can be used as an alternative to a traditional group plan offered through an employer because an employee can use it to purchase healthcare coverage on the marketplace and then be reimbursed for their insurance premiums along with other eligible medical expenses.

Because of the flexibility these plans offer and the fact that they can be used by employers of any size, they are finding favor amongst the agriculture, hospitality, and restaurant industries. Employers can offer this type of account to all their employees or different classes of employees within their organization, but they cannot offer an ICHRA to an employee who is also offered a traditional health plan. Small and mid-sized companies may decide to offer an HRA in place of a traditional health plan to give employees more affordable options. Larger companies can offer them to different classes of employees to reduce costs by avoiding Applicable Large Employer taxes, fees and penalties. The groups an employer to whom an employer can offer an ICHRA include:

Salaried employees
Hourly employees
Full-time employees
Part–time employees
Seasonal employees
Employees covered by collective bargaining unit
Employees who have not satisfied a coverage waiting period
Nonresident aliens with no US-based income
Employees of an entity that hired the employees for temporary placement at another entity (temporary worker rule)
Employees whose primary site of employment is in the same rating area. The rating area is defined as the rating area used for ACA premium rating requirements in the individual market. This allows employers to offer or vary benefits based on worksite location.
Any combination of two or more of the above classes.

There is no reimbursement maximum, but employers can determine a cap. Employees and covered family members must enroll in individual health plans or Medicare for every month that they are enrolled in an ICHRA. (It just cannot be short-term, limited-duration insurance.) ICHRA benefits are also pre-taxed, just like traditional healthcare benefits, so any reimbursement from an employer does not count toward an employee’s taxable wages.

ICHRAs provide more flexibility for employers and provide many people with more options for affordable health care, including those employed by small businesses, as ICHRAs can be offered by employers of any size. Many employers offer only one health plan to their employees; an ICHRA would allow employees to shop around for the coverage that best meets their needs.

What is a QSEHRA?

QSEHRA stands for Qualified Small Employer Health Reimbursement Arrangement. While this benefit has been around for , with the release of ICHRA accounts, it has recently received more attention as a way for small businesses and non-profit organizations to offer healthcare coverage to their staff, as well. Like a traditional HRA, these accounts are not health insurance coverage, but they help offset the costs for medical expenses, including premiums.

A QSEHRA allows employers to set aside a certain amount of money each month to reimburse employees for healthcare expenses, whether insurance premiums or other medical expenses, and the reimbursements are available tax-free for everyone. This means employers can offer benefits without having to administer or pay the hefty costs associated with a traditional group health plan, and employees can choose a health plan that works best for their needs.

A QSEHRA is a great option for several reasons. Not only does it allow employers to control and specifically budget how much money is allocated to healthcare coverage each year, it also gives employees the freedom to choose what works for them. Many traditional group plans can feel like a one-size-fits-all solution that doesn’t adequately meet everyone’s needs. With a QSEHRA, employees can choose their own health plan or use the reimbursement funds to cover premiums for coverage on a spouse’s health plan. Because they are tax free, they make more money available to employees than what they would receive through a health stipend or a salary increase.

HRA Administration

The current Special Enrollment Period is the perfect opportunity to structure new benefit plans. Comparative Solutions can help you set up and manage your HRA accounts so that employees can use this SEP to choose health plans that fit their needs and budget. From verifying eligibility and handling reimbursement claims to providing notices and keeping records, we will manage the details, so you can focus on managing your business. Not only do we offer HRA administration, but we also provide Commuter, HSA, FSA, Compliance, and COBRA benefits administration. Whatever you're looking for, we've got you covered. Contact Comparative Solutions today to get the ball rolling!

COVID-19: What's Next?

Tue, 23 Feb 2021 22:38:46 -0800

With the Outbreak Period now set to expire February 28, several important COBRA deadlines are expected to restart.

In March 2020, the country became rapidly consumed with the COVID-19 healthcare crisis. As new cases began to multiply, the U.S. government formally declared the outbreak a public health emergency. Since that time, Americans have been flooded with significant healthcare and economic concerns as nearly every industry has been affected. Millions of workers have been laid off or furloughed, resulting in the loss of healthcare coverage. This has emphasized the need for COBRA coverage as a short-term solution for those dealing with new job searches in a depressed market who still need to have healthcare coverage for themselves and their family.

In response to the significant number of layoffs and furloughs and the sharp increase in COBRA participants, Congress has approved special measures to address the loss of employer-sponsored health coverage. While these new measures are in place from March 2020 until the Outbreak Period ends, that period is now set to expire February 28, causing several important COBRA deadlines to restart.

New COBRA Measures

Typically, the following COBRA rules apply:

Election period: When a beneficiary experiences a qualifying event (loss of job, reduction in hours, death of covered employee, etc.), they have 60 days to choose whether to elect COBRA coverage.
Premium payments: Plans must allow premium payments to be made in monthly installments, and the first payment is not due until 45 days after COBRA was elected. If a beneficiary does not to pay on time, they can lose coverage. However, premiums are still considered on time if they are made no more than 30 days after the first day of the premium coverage period.
Notifications: Once a beneficiary has a qualifying event, the employer must notify the plan administrator within 30 days. Benefit plan administrators then have 14 days to send notices of continuing coverage to the beneficiary. Once a beneficiary has a qualifying event, the employer must notify the plan administrator within 30 days.

However, due to the large number of layoffs and furloughs COVID has produced, plans have been required to disregard the period from March 1, 2020 until 60 days after the announced end of the National Emergency (the “Outbreak Period”) in determining the following periods and dates:

60-day election period for COBRA continuation coverage

COBRA continuation coverage premium payments COBRA continuation coverage premium payments

Notification date for individuals to tell a health plan of a qualifying event or disability Notification date for individuals to tell a health plan of a qualifying event or disability
Date for providing a COBRA election notice from group health plan sponsor or administrator

After the Outbreak Period

COBRA enrollment has dramatically increased over the past 10 months and may continue for the foreseeable future. Overseeing the many stop and start dates, deadlines, payments, notices, and communications for so many individuals creates an enormous compliance burden for COBRA administrators. With the February 28 date rapidly approaching, administrators need to be aware of several scenarios that could play out.

The Outbreak Period ends and there are no subsidies. One possibility is that Congress will let the period end and without approving any financial assistance to those in need. While this would start the 60-day COBRA clock for payments, elections, and notices, the economy and the job market is still depressed. Millions of people could find themselves without a job, without a way to pay for COBRA premiums, and, therefore, without health insurance.

The Outbreak Period is extended temporarily. Another possible outcome is that the federal government will approve a temporary extension, giving people who have not been able to find employment more time to keep their healthcare coverage. It could also give Congress additional time to agree on a plan to subsidize COBRA payments. If this happens, it will extend dates for making payments, providing notices, etc.

The current Outbreak Period ends and Congress approves a new Outbreak Period, with or without subsidies. If this happens, the current Outbreak Period could expire, starting the current 60-day clock for COBRA timelines. Then, new legislation could designate a second Outbreak Period with a new date for starting the 60-day COBRA timeline clock. It could also include COBRA subsidies, either tied to a new timetable or applied retroactively to the previous Outbreak Period.

Legislation for COBRA Subsidies May Be Coming

COVID-19 has wreaked havoc on Americans, both medically and economically. In addition to the stress of losing employment and healthcare coverage, many beneficiaries could find themselves wondering how they will pay for the COBRA premiums that have been stacking up during this Outbreak Period. Many organizations have been urging Congress to offer COBRA subsidies for months. President Joe Biden has now joined in, calling on Congress to subsidize COBRA premiums in his proposed “American Rescue Plan”. This plan would subsidize COBRA premiums, by way of a 100 percent tax credit, through September 30, 2021. Another current proposal, the “Worker Health Coverage Protection Act”, would subsidize COBRA premiums 85 percent. Under this proposal, employers will be reimbursed through a credit to their payroll tax liability. These subsidies could allow millions of people to keep their healthcare coverage while searching for new employment.

Alleviating the Administrative Burden

With COBRA participation spiking as millions of people have lost their employer-based health coverage, COBRA administrators can find the upcoming 60 day window overwhelming, especially as the Outbreak Period draws to a close. Let Comparative Solutions help. Our trusted benefit advisors can provide you with peace of mind in navigating the potential scenarios that could arise over the coming weeks. From election notices to premium payments and keeping records, we manage the details of COBRA administration, helping you stay on top of all the changes and helping participants maintain access to healthcare coverage.

Comparative Solutions is a full service TPA proudly based in the Pacific Northwest. With over a decade of experience working with brokers and employers, we provide Commuter, FSA, HRA, HSA, and COBRA benefits administration, as well as Compliance Administration. Whatever you're looking for, we've got you covered. Call or email us today, and let us find the right solution for you!

Did You Know? New COVID-19 Guidance For Health Benefits

Thu, 11 Feb 2021 22:01:48 -0800

The world looks much different than it did a year ago. The impacts of COVID-19 have been far-reaching – extending into the way we get our groceries, go to school, and even greet loved ones. The rules of engagement have changed. Managing health benefits is no exception. Over the last year, the federal government has made a number of legislative changes to health benefit coverage due to COVID-19. While these new changes provide more comprehensive and long-term coverage during the pandemic, making sense of them has proven a difficult task, and keeping track of them has been overwhelming for administrators.

With the constant flow of information being released, it is easy to miss some significant benefit changes. We have created a list of highlights to provide you with clear guidance in making benefit decisions.

Did You Know:

Several impactful new COBRA extensions have been released, including:

Deferred COBRA Election Notices: Usually, benefit plan administrators are required to send notices of continuing coverage within 14 days of a qualifying event. However, due to the large number of layoffs and furloughs COVID has produced, employers now have up to 60 days after the Outbreak Period ends to provide election notices to qualified beneficiaries. *The Outbreak Period runs from March 1, 2020 until 60 days after the announced end of the state of national emergency caused by the COVID-19 pandemic.
Larger COBRA Election Window: Those eligible to enroll in a COBRA plan now have an increased window to do so. Because the COBRA election period has been postponed, after a qualifying event, individuals may not be denied coverage, even if they haven’t enrolled in COBRA yet. This not only means that qualified beneficiaries have more opportunity to shop around for different coverage for themselves, but they also have a much larger amount of time than the traditional 60-day window to deny COBRA coverage and then reverse that decision.
Deferred COBRA Payments: COBRA account holders can now defer their premium payments as they, too, have been postponed during the Outbreak Period. Those newly enrolled are not required to make payment until 60 days after the Outbreak Period ends, while those already enrolled can defer until 30 days after the Outbreak Period has ended.

Midyear Election Changes: The IRS will allow more flexibility in making mid-year changes to Section 125 cafeteria plans. Typically, selections must be made on the first day of the plan year and can rarely be changed. However, due to the impacts of COVID-19, the IRS will allow employees to make mid-year election changes, including:

Enrolling in employer-sponsored health coverage if it was initially offered and declined.
Switching to a different employer-sponsored health plan.
Withdrawing from their current plan if they provide a written statement saying they are enrolled in (or will immediately enroll in) a health plan that is not provided by their employer.
For FSA and dependent care programs, revoking their plan choice, or changing their contribution to their current FSA or dependent care program account.

Telehealth Services: HDHPs with HSAs may now cover the cost of telehealth appointments and services before the plan deductible has been met. This will be in effect until 12/31/21.
HRA Reimbursement: According to the IRS, a health plan can reimburse an individual’s policy premiums for charges acquired “before the beginning of the plan year for coverage provided during the plan year.” This means that you can utilize the benefits of the individual coverage HRA (1) the first of the month of coverage, (2) the first day of actual coverage, or (3) the date premium is paid.
HDHP Coverage: If employees are enrolled in an HDHP plan, they can have the testing and treatment of COVID-19 waived before meeting their deductible. If the health plan is classified as an HDHP but will cover the testing and medical treatment of COVID-19 before the deductible has been met, it will still qualify as an HDHP. This will allow those enrolled in HDHPs to keep their coverage without jeopardizing their HSA eligibility.
FSA Rollover Increase: The IRS has permanently increased the amount individuals with FSA accounts can roll from one year to the next. The carryover amount for health FSAs, which was previously $500, has increased to $550.
Expansion of Reimbursable Expenses: Over the counter Medications can once again be reimbursed through HSA and FSA accounts without a prescription. Account holders can be reimbursed for these items regardless of whether they are being used to treat COVID-19 related illness. This is a permanent change.
Menstrual Care Products: Menstrual care items purchased after December 21, 2019 are now a qualified medical expense. They are covered by HSA and FSA accounts, and they are eligible for reimbursement if they were purchased after 12/21/19. This is in effect indefinitely.

Understanding health benefits and providing the best options to employees was a challenge even before COVID-19. Now keeping pace with all the new benefit changes can feel overwhelming. Let Comparative Solutions help you manage the adjustments. From midyear election changes and handling reimbursement claims to providing notices and keeping records, we manage the details of benefit coverage, so employees have access to the healthcare they need without any of the confusion that usually accompanies change.

Comparative Solutions is a full service TPA proudly based in the Pacific Northwest. With over a decade of experience working with brokers and employers, we provide Commuter, FSA, HRA, HSA, and COBRA benefits administration. Whatever you're looking for, we've got you covered. Call or email us today, and let us find the right solution for you!

New Special Enrollment Period Coming Soon

Mon, 08 Feb 2021 22:07:05 -0800

Usually, individuals can only enroll in healthcare during the annual Open Enrollment period that typically occurs in November each year or when they experience a qualifying event, such as a change in employment or marital status. However, due to the current health crisis, the Federal and State Exchange will be allowing people another opportunity to enroll in a health plan if they did not choose to purchase healthcare coverage during the annual Open Enrollment period. It is important to note that those who are currently enrolled in a healthcare plan through the exchange cannot change plans unless they experience a qualifying event.

All marketplaces using the Healthcare.gov platform, or their state’s platform, are adopting the same flexibility of the Federal Exchange, making it easier for people looking for coverage to enroll in the right plan to meet their needs, according to the Centers for Medicare and Medicaid Services.

If you are uninsured and would like to take advantage of this special enrollment period, let us help! Comparative Solutions is a group of insurance enthusiasts who thrive helping people understand insurance. With over a decade of experience, we can help you find the right plan for your needs and budget. We simplify insurance, handling all the red tape and confusing language for you and saving you time and money in the process. The best part? We do not charge our clients for our services. There is never a cost to work with us. If you already have an account through the Washington Health Plan Finder, we can still guide you through the process. You can simply connect to us as your broker for year-round assistance. Call or email us today, and let us find the right solution for you!

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