IMPORTANT REMINDER TO MULTIPLE EMPLOYER WELFARE ARRANGEMENTS (MEWAs):  The Form M-1 must be filed no later than March 1 following any calendar year for which a filing is required.  A one-time extension of time to file will automatically be granted if the administrator of the MEWA requests an extension.  More filing information is available on the US DOL (EBSA) website:  https://www.askebsa.dol.gov/mewa/.

If you sponsor a limited scope health FSA or limited scope HRA that covers post-deductible expenses, the claims substantiation rules require independent third party substantiation.  The substantiation incudes demonstrating that the individual whose expense is submitted for reimbursement has satisfied the deductible.  This could be satisfied through submission of an Explanation of Benefits (EOB) showing satisfaction of the applicable deductible.  A  mere statement by the participant that he/she has satisfied the deductible is not sufficient.

If you have any questions or would like additional information, please contact us.

For an applicable large employer (ALE) completing Form 1095-C, a former employee that has coverage (e.g., COBRA, state continuation, retiree coverage, etc.) is coded as 1H for line 14  and 2A on line 16 for the months in the year in which the termination of employment occurs, and 1G for line 14 for months in the year(s) following the year in which the termination of employment occurs.  If the coverage is self-insured, Part III needs to be completed as well.

If you have any questions or need assistance with ACA compliance, please contact us.