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Summary Annual Reports Due Sept. 30

Health plans with 100 or more plan participants at the beginning of a plan year are generally required to furnish a Summary Annual Report (SAR) to each health plan participant within 9 months after the end of a plan year. As a result, the deadline for most calendar year plans to satisfy the SAR requirement for plan year 2017 is September 30, 2018.

What Must be in a SAR?
A SAR serves as a narrative summary of the group health plan's Form 5500 annual report. In general, a SAR must provide the following information on the plan year (among other things):

  • Name of the insurer
  • Total premiums paid
  • Value of plan assets at the beginning and end of the plan year
  • Amount of plan expenses

Is a Model Notice Available?
While the U.S. Department of Labor has not released a model SAR, federal regulations provide model language. To review this model language, click here and see the section titled "Form for Summary Annual Report Relating to Welfare Plans."

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Medical Loss Ratio Rebates Coming Soon to Plan Sponsors

 

The Affordable Care Act's medical loss ratio (MLR) rules require group health insurance issuers to provide rebates if their MLR - the percentage of health insurance premiums spent on health care and activities to improve health care quality - falls short of the applicable standard during a reporting year. Each year's rebates must be issued to plan sponsors by September 30 of the following year. As a result, plan sponsors should be looking for these rebates to arrive in the coming weeks.

 

Employer Distribution
The MLR rules provide that issuers must pay any rebates owed to persons covered under a group health plan to the policyholder, who is then responsible for distributing the rebate to eligible plan enrollees. In general, there are several ways rebates may be distributed by plan sponsors to plan enrollees, including:

  1. A rebate check in the mail;
  2. A lump-sum reimbursement to the same account that was used to pay the premium if it was paid by credit card or debit card; or
  3. A direct reduction in future premiums.

In addition to the above methods, employers may also apply the rebate in a way that benefits employees. However, decisions on how to apply or expend the plan's portion of a rebate are subject to the general standards of fiduciary conduct under the federal Employee Retirement Income Security Act (ERISA).


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If you work with us, you can expect us to:

  • Challenge assumptions and the status quo
  • Push your Human Resources Function to move beyond where you are today
  • Identify the challenges of your Human Resources Function and look for new solutions that will drive opportunities
  • Educate as we go, leaving your team more capable and more independent
Top 5 New Hire Forms

An employee's first day on the job can be very stressful for both the employee and employer. While trying to set up the employee with his or her parking pass, email account, and other necessities, employers should also remember that completing the following forms is just as important.

  1. Form I-9: Under federal law, employers are required to verify the identity and employment authorization of each person they hire by completing and retaining Form I-9. Newly hired employees must complete and sign Section 1 of Form I-9 no later than the first day of employment. Click here to download Form I-9.
  2. Federal Form W-4: An employee must complete federal Form W-4 in order for the employer to withhold the correct federal income tax from the employee's pay. Click here to download federal Form W-4.
  3. State Form W-4: In states with a state income tax, an employee must complete a state Form W-4 or its equivalent in order for the employer to withhold the correct state income tax from the employee's pay. To obtain a state Form W-4, contact your state's taxation department.
  4. Basic Employment Information Sheet: Employers should keep certain basic information about each of their employees on file, including their addresses, phone numbers, and emergency contacts. Click here to download a Basic Employment Information Sheet.
  5. Direct Deposit Authorization Form: It is now easier than ever for an employer to directly deposit an employee's paycheck into his or her bank account. Such deposits, however, must be specifically authorized by the employee. Click here to download a Direct Deposit Authorization Form.
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How Summer Hires May Impact Your ALE Status

Employers that hired seasonal workers this summer are reminded that there is a seasonal worker exception when measuring workforce size to determine whether they are an applicable large employer (ALE) subject to the Affordable Care Act's employer shared responsibility ("pay or play") provisions.

 

Seasonal Worker Exception
The pay or play provisions generally require ALEs - generally those with at least 50 full-time employees, including full-time equivalent employees (FTEs) - to offer affordable health insurance that provides a minimum level of coverage to full-time employees and their dependents in order to avoid paying a tax. However, if an employer's workforce exceeds 50 full-time employees (including FTEs) for 120 days or less (or 4 calendar months) during the preceding calendar year, and the employees in excess of 50 who were employed during that period were seasonal workers, the employer is not considered an ALE for the current calendar year. A seasonal worker for this purpose is an employee who performs labor or services on a seasonal basis. For example, retail workers employed exclusively during holiday seasons are seasonal workers.

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HR Fuzion, LLC - All rights reserved | 105 W. Kansas St, Suite B | Liberty, MO 64068 | 816.654.6800

Please Note: The information and materials herein are provided for general information purposes only and are not intended to constitute legal or other advice or opinions on any specific matters and are not intended to replace the advice of a qualified attorney, plan provider or other professional advisor. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy. In accordance with IRS Circular 230, this communication is not intended or written to be used, and cannot be used as or considered a 'covered opinion' or other written tax advice and should not be relied upon for any purpose other than its intended purpose.

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