Tag: HRAs

Sterling Updates: Important Changes for 2012

We’re pleased to announce new services at Sterling Health Services Administration, as well as share reminders about important industry changes in 2012.

New Sterling Services:

  • Login Once for Access to HSA, HRA and FSA Accounts – We’ve made it easier for you to access account information online. If you have multiple accounts with Sterling, such as an HSA and HRA, or HSA and FSA, just one login at www.sterlinghsa.com now provides access to account information and transaction tools for HSAs, HRAs and FSAs. You may remember that each product required a separate login until now. At this time, COBRA account access still requires a separate login to our WebCOBRA portal. Product web guides with more details can be downloaded by clicking the buttons below.
  • Fast Account Balances Via Phone – You can get your HSA,HRA and FSA account balances anytime just by calling 800-617-4729, pressing 1 at the prompt, and entering your Sterling account number. The response to this new service has been very positive, making it easy for you to access information on funds available anytime from anywhere.

Industry Updates:

  • HSA contribution limits for 2012 increased to $3,100 for individuals and $6,250 for families, regardless of the health plan deductible. Accountholders over 55 can make a $1,000 annual catch up contribution as well.
  • For Transit and Parking FSAs, the 2012 benefit amounts are $240 per month for parking (a $10 monthly increase) and $125 per month for transit (down from $230).

If you are a Sterling Accountholder or Subscriber, download your web portal guides below:

FSA Employee Guide
HRA Employee Guide
HSA Employee Guide

If you are a Sterling Employer Client, download your web portal guides below:

FSA Employer Guide
HRA Employer Guide
HSA Employer Guide

Questions? Contact Sterling customer service by calling 800-617-4729 or emailing customer.service@sterlinghsa.com. Now through February 2012, we have extended customer service hours and are available to help you from 6 am to 8 pm PT.

Legislative Update: CMS Changes Reporting Requirements For Some HRAs

The Centers for Medicare and Medicaid Services (CMS) has issued an Alert that modifies Medicare Secondary Payer (MSP) reporting requirements for Health Reimbursement Arrangements (HRAs).

Background

Beginning in the fall of 2010, HRA administrators have been required to submit participant data to CMS quarterly so that CMS can determine if Medicare is primary or secondary coverage to an employer-provided HRA.

Key Changes

  • New or renewing HRAs with an effective date on or after October 3, 2011 do not have to be reported if the maximum annual reimbursement is less than $5000.
  • Existing coverage in an HRA will be subject to reporting until the beginning of the next plan year (a notice of termination is still required for an existing HRA participant who terminates employment and thus loses coverage on or after October 3, 2011) but newly eligible participants do not have to be reported if the effective date of the coverage is on or after October 3, 2011.
  • A notice of termination must be reported for all HRA participants who exhaust their funds during the year to the extent no additional funds will be added.  The participants would be once again added as a new record at the beginning of the next plan year if the HRA reimbursement exceeded $5000.

The full CMS Alert can be found here: http://www.cms.gov/MandatoryInsRep/Downloads/HRACoverage.pdf

Employer Compliance Update: June 30 Deadline for FSA, HRA & HSA Amendments

Last year’s Affordable Care Act (ACA) restricted the ability of employer health plans, including flexible spending arrangements (FSAs) and health reimbursement arrangements (HRAs), to reimburse expenses incurred for over-the-counter (OTC) medications.  Funds from these accounts can no longer be used to purchase items like aspirin, allergy and cold medications without a written doctor’s prescription. The pharmacist must fill prescriptions for these  items to be qualified expenses. There are still many over-the-counter medical products that can be purchased using FSA, HRA and HSA funds without a  doctor’s prescription. Examples include contact lens solutions and diabetic test kits and supplies. Accountholders should check before they purchase.

Sponsors of FSAs face a June 30, 2011 deadline for amending their plans to comply with this ACA restriction.This restriction actually became effective as of January 1, 2011. Ordinarily, the IRS requires that FSA amendments be adopted before they take effect.  Moreover, proposed IRS regulations state that any failure to satisfy this requirement results in all employee contributions to the FSA becoming taxable.  Perhaps recognizing the severity of this result, the IRS in Notice 2010-59 granted FSA sponsors an additional six months to adopt amendments designed to comply with this restriction.  That six-month extension expires on June 30, 2011.

A similar restriction applies to the reimbursement of expenses for OTC medications under health savings accounts (HSAs).  However, the consequences of non-compliance under such arrangements differ from those that apply under FSAs or HRAs.  Distributions from an individual’s HSA for OTC medications that are not prescribed by a physician are treated as “nonqualified” distributions.  They are therefore includible in the individual’s taxable income, and also subject to a 20% penalty tax.

All Sterling Health Services Administration Employers are in compliance.
No action is necessary on the part of Sterling Employers.

In amendments to their FSAs or HRAs, employers need to keep in mind several key points.  First, such an amendment should be retroactively effective as of January 1, 2011.  This date applies regardless of an arrangement’s plan year, and even if an FSA has been amended to take advantage of the two month “grace period” allowed by the IRS.  However, any expenses for OTC medications that were incurred before January 1, 2011, may still be reimbursed after that date, even without a prescription.

Another point to be addressed in any FSA or HRA amendment involves the treatment of OTC items other than medications.  Notice 2010-59 made clear that expenses for equipment (such as crutches), supplies (such as bandages), and diagnostic devices (such as blood sugar test kits) may still be reimbursed under an FSA or HRA, even without a prescription.  In other words, the prescription requirement applies only to OTC medications.

Finally, any amendment to an FSA or HRA that allows participants to use debit cards to purchase OTC medications should take into account additional IRS guidance.  For instance, Notice 2010-59 granted such arrangements an additional fifteen days (through January 15, 2011) to comply with the requirement of a physician’s prescription for an OTC medication.  IRS Notice 2011-5 then outlined specific procedures that must be followed if debit cards will continue to be an option for the purchase of OTC medications after January 15, 2011.  In general, these procedures are designed to ensure that these cards can be used to purchase OTC medications only after a prescription has been obtained.

As stated earlier, all Sterling Health Services Administration Employer clients are in compliance and no action is necessary on your part. If you have any questions or concerns, please contact us at 800.617.4729.

Hatching a Bill to Take HSAs to a New Level

President of HSA Consulting Services and author of The Common Sense Guide to Health Savings Accounts, Ro y Ramthun recently contributed this article to CDHC Solutions – the member-based networking community for the consumer-driven health care industry and audience of CDHC Solutions magazine. CDHC Solutions hosts the latest industry news, newest innovations, best practices, and recent trends in addition to supplying a platform for employers, consumers, and health care solutions providers to interact and discuss consumer-directed health care commerce (CDHC).

The article discusses the upcoming introduction of a new bill which presents several key potential changes to health savings accounts (HSAs), as well as flexible spending accounts (FSAs) and health reimbursement arrangements (HRAs).

Hatching a Bill to Take HSAs to a New Level

By Roy Ramthun, President of HSA Consulting Services

Health Savings Accounts (HSAs) continue to grow as businesses look for ways to control employee benefit costs. While this trend should not change under the new health reform law, there have been some technical issues not addressed in the Tax Relief and Health Care Act of 2006 (P.L. 109-432).

That could change soon because Sen. Orrin Hatch (R-Utah) will be introducing a bill that will help take HSAs to another level, regardless of whether the health reform law is repealed or stays in place. This bill is significant because Sen. Hatch will be the highest ranking GOP member of the U.S. Senate Committee on Finance, which has legislative jurisdiction over the Internal Revenue Code, where HSAs were created. Sen. Hatch could also become the Committee’s next Chairman, depending on the outcome of upcoming elections in 2012.

The bill also would repeal the two most egregious provisions relating to consumer-driven health care in the new health reform law. First, the bill would repeal the limitation on tax-free reimbursement of over-the-counter medicines without a prescription for HSAs, as well as Flexible Spending Arrangements (FSAs) and Health Reimbursement Arrangements (HRAs). Second, the bill would repeal the limitation on deductibles imposed at $2,000 for single coverage and $4,000 for family coverage under plans offered by small businesses.

Changes to HSA Eligibility
Once a person turns 65, they usually no longer contribute to their HSA because of automatic enrollment in Medicare Part A. However, the current deductible for hospital coverage under Medicare Part A is very high, almost $1,200 per admission, nearly equal to the minimum deductible required for HSA-qualified plans. The Hatch bill would allow Medicare beneficiaries enrolled only in Part A to continue to contribute to their HSA accounts.

Great Flexibility in Using HSA Funds
Currently, people may only use their HSA account to pay for health insurance premiums when they are receiving federal or state unemployment benefits or are covered by a COBRA continuation policy from a former employer. The Hatch bill would allow HSA funds to be used to pay premiums for HSA-qualified policies under any circumstances.  The Hatch bill also would allow HSA funds to be used to reimburse all qualified medical expenses incurred after HSA-qualified coverage begins as long as the account is established by April 15 of the following year. Currently, expenses incurred before one’s HSA account is established cannot be reimbursed tax-free.

To help people stay healthy, Sen. Hatch’s bill would allow HSA funds to be used for new types of expenses, including:

  • Exercise and physical fitness programs (up to $1,000 per year)
  • Nutritional and dietary supplements, including meal replacement products (up to $1,000 per year)

Some primary care doctors are charging patients a flat annual fee in exchange for the right to receive medical services on an “as-needed” basis through the year. Currently, the IRS does not permit HSA funds to be used to pay these fees because there is no direct billing for individual services provided by the physician and the arrangement is not considered “insurance.” The Hatch bill would allow HSA funds to be used to pay these annual fees.

Rollovers and Catch-Up Contributions
The changes made by Congress in 2006, though well-intended, make it very difficult for employees to ever be able to roll over unused funds in an FSA or an HRA to help fund their HSAs. The Hatch bill simplifies the process for rollovers in order to ease the transition to HSAs from FSAs and HRAs.

HSA-eligible individuals age 55 or older may make additional catch-up contributions of $1,000 each year. However, the contributions must be deposited into separate HSA accounts even if both spouses are eligible to make catch-up contributions. The Hatch bill would allow married couples to put their catch-up contributions into one account.

Expanded Definition of “Preventive” Drugs
HSA-qualified plans may cover preventive care services without applying the policy deductible. Although the IRS allows certain types of prescription drugs to be considered “preventive care,” it generally does not permit plans to include “maintenance drugs” taken by persons with chronic conditions. The Hatch bill would provide additional flexibility to health plans that want to provide coverage for these medications and remove a perceived barrier to HSAs for people with chronic conditions.

About the Author:
Roy Ramthun is President of HSA Consulting Services, a health care consulting practice specializing in Health Savings Accounts and consumer-driven health care issues. Prior to forming his consulting practice, Ramthun was the Special Assistant to the President for Economic Policy at the White House. As a member of the National Economic Council staff, Ramthun was the senior health policy advisor to President George W. Bush regarding health care issues involving the Internal Revenue Code (primarily HSAs), Medicare, Medicaid, and the Federal Employees Health Benefits Program.

Click here to access the original publication of this article.


Sterling Health Services Administration
What do you think about these proposed changes? We would enjoy hearing your comments.

Watch for updates on this bill – and other healthcare reform issues – on our website and our Facebook page, as well as on this blog.