In their Employee Benefits January Newsletter, NYSTIA Member Brown & Brown Inc. provided important guidance on a number of issues, most notably:
Creditable Coverage Disclosure to CMS due March 1, 2023
Each year, group health plan sponsors that provide prescription drug coverage to individuals eligible for Medicare Part D must electronically disclose to the Centers for Medicare & Medicaid Services (CMS) whether that coverage is "creditable" or "non-creditable." The disclosure obligation applies to all plan sponsors that provide prescription drug coverage, even those that offer prescription drug coverage only to active employees and not to retirees. The Online Disclosure to CMS form on an annual basis. The Disclosure to CMS is due no later than 60 days after the beginning date of the plan year (contract year, renewal year, etc.) and upon change of the plan’s creditable coverage status. Calendar-year plans must submit this year's disclosure to CMS by March 1, 2023.
2023 Telemedicine & HSA Relief
The 2023 Consolidated Appropriations Act (CAA 2023) includes verbiage that extends temporary relief permitting telemedicine plans to be offered in combination with Health Savings Accounts (HSA) without including a deductible or charging a fair market value (FMV) fee. The bill has now been signed into law by President Biden with the telemedicine/HSA relief language intact.
Calendar year plans can take advantage of the relief right away without disruption. Employees with Health Savings Accounts can participate in a telemedicine plan with no cost-sharing and remain HSA eligible for both the 2023 and 2024 plan years. Unfortunately, the CAA 2023 creates a gap in the relief for non-calendar year plans.
On December 21, 2022, Governor Hochul approved the Pay Disclosure Law NY S9427A requiring businesses to disclose salary ranges for advertised jobs and promotions. Covered employers will be required to maintain records, including the history of pay ranges for each job, promotion and transfer opportunity and the associated job descriptions.
NYSTIA member Mike Mastroleo is happy to connect with anyone who has questions or may need guidance with Employee Benefits.
Contact Mike with your needs or questions:
Employee Benefits Consultant
Office: 315 671 8882 Cell: 315 430 2147
Brown & Brown partners with most small & large size companies.