In an article published by HR Professionals, Bass, Berry & Sims attorney Susie Bilbro provided insight on aspects plan sponsors should consider as they prepare for the 2018 open enrollment process. Among the key questions Susie suggests sponsors to ask themselves in the upcoming months are:
Are you including the right disclosures in your open enrollment materials? There are multiple participant disclosure requirements for employee welfare benefit plans that plan sponsors must be aware of during the eligibility or enrollment processes, and on an on-going basis. Some of these items are summary plan descriptions (SPDs), COBRA notices, HIPAA notices and Medicare Part D notices.
Is your cash in lieu of benefits payment program compliant? While some plan sponsors are offering cash payments to employees who agree to waive employer-sponsored health coverage, employers should be aware of excise taxes for non-compliant opt-out arrangements and the impact of opt-out arrangements on affordability calculations.
What do you need to know (and tell employees) about your HSA? Health savings accounts (HSAs) have a contribution limit for 2018 of $3,450 for individual accounts and $6,900 for family coverage. HSAs are triple-tax-advantaged, because HSA deposits are tax-free, contributions grow tax-free, and distributions are tax-free for out-of-pocket and qualifying expenses. Individuals with a flexible savings account (FSA) are ineligible to contribute to an HSA, and certain FSA design features may affect HSA eligibility for subsequent years.
The full article, "Open Enrollment Considerations for Plan Sponsors," was published in the August 2017 edition of HR Professionals and is available online.