Human Resources

The Washington Report

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January 23, 2019


CMS Issues Proposed Rule on Payment Notice for 2020 Coverage Year

On January 17, 2019, the Department of Health and Human Services’ Centers for Medicare and Medicaid Services (CMS) released a proposed rule on the Notice of Benefit and Payment Parameters for the 2020 benefit year. This rule proposes regulatory and financial parameters applicable to qualified health plans on the Exchanges, plans in the individual, small group, and large group markets, and self-funded group health plans. The rule proposes changes that would allow greater flexibility related to the duties and training requirements for the Navigator program and changes that would provide greater flexibility for direct enrollment entities, while strengthening program integrity oversight over those entities. Additionally, the rule proposes policies that are intended to reduce the costs of prescription drugs and includes proposed changes to Exchange standards related to eligibility and enrollment; exemptions; and other related topics. Comments on the proposed rule are due no later than February 19, 2019.

The proposed rule is temporarily available here.
(The rule will be published in the January 24, 2019, Federal Register.)

The CMS news release is available here.

A fact sheet on the proposed rule is available here.

Other HR/Employment

IRS Releases Revenue Procedure on Determination of W-2 Wages

On January 18, 2019, the Internal Revenue Service (IRS) released Revenue Procedure 2019-11, which provides methods for calculating W-2 wages, as defined in Section 199A(b)(4) and Section 1.199A-2 of the Income Tax Regulations: (1) for purposes of Section 199A(b)(2) of the Internal Revenue Code, which, for certain taxpayers, provides a limitation based on W-2 wages to the amount of the deduction for qualified business income; and (2) for purposes of Section 199A(b)(7), which, for certain specified agricultural and horticultural cooperative patrons, provides a reduction to the Section 199A deduction based on W-2 wages.

Revenue Procedure 2019-11 is available here.

Aon Publications

2019 Medicare Part D Disclosure Reminder

This Aon bulletin is a reminder of an annual disclosure requirement applicable to most employers that provide prescription drug coverage to individuals who are Medicare Part D-eligible. This disclosure is not new and should have occurred each year since 2006. The disclosure applies regardless of whether an employer provides retiree prescription drug benefits.

For 2019 calendar year plans, the disclosure must occur no later than March 1, 2019. The annual disclosure must occur for any employer that provides prescription drug coverage to anyone who is Medicare Part D-eligible.

The Aon bulletin is available here.

IRS Issues Form 8994 on the Paid Family and Medical Leave Tax Credit

The Internal Revenue Service (IRS) recently issued Form 8994 (Employer Credit for Paid Family and Medical Leave) and instructions on the paid family and medical leave (FML) tax credit pilot program that was enacted in 2017. Under the pilot program, employers that provide paid FMLA benefits to certain employees in 2018 and 2019 are eligible for a general business tax credit under Code Section 45S. Form 8994 is to be filed with an employer’s corporate tax return and IRS Form 3800 (General Business Credit).

The Aon bulletin, which provides a brief overview of Form 8994 and information for employers, is available here.

Aon Publications on Federal Developments in 2018

Aon provided insights into numerous developments last year that had an impact on employer-provided health plans, retirement plans, sick leave, family and medical leave, disability benefits, wellness plans, overtime, and other areas of employee benefits and human resources affecting employers. Many of these developments consisted of regulations, notices, court decisions, questions and answers, and reporting and disclosure guidance issued by federal agencies. This report gathers together the Aon bulletins that summarized and analyzed significant developments in 2018, with direct links to the publications.

The Aon bulletin is available here.

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