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HIPAA (continued from page 21)
Law
Compliance Plans Compliance Amendment
Snapshot Affected Deadline Required or
Merely
Change in
Administration
Qualified Adds a new transportation Transit Fringe Benefit Effective January Amendment
Bicycle fringe benefit for employer Plans. No pre-tax 1, 2009 recommended if
Commuting funded reimbursement of employee salary reduc- benefit offered.
Reimbursement up to $20 per month for tions allowed; benefit
under Energy reasonable expenses must be 100% employ-
Improvement incurred for commuting to er-funded. Participants
and Extension work with a bicycle. in qualified bicycle
Act benefit may not partici-
of 2008 pate in a qualified
transportation plan.
Medicare Registration and quarterly Health plans January 1, 2009— Administration
Secondary reporting by responsible (including HRAs) data collection changes.
Payer (MSP) reporting entity (RRE) to begins for covered
Reporting Centers for Medicare and plans. RREs
Rules Medicaid Services (CMS) on should register
“Active Covered Individuals”
for secondary payer coordi- 4th quarter 2010—
nation. Generally, the TPA first quarterly
will be the RRE if the TPA report due for
pays and/or adjudicates HRA coverage
claims for the plan, even if information
the plan is self-insured. FSA
and dental only administra-
tors should be exempt. HRA
administrators are subject to
these requirements.
Parity for The maximum statutory Transit Fringe Prospectively Amendment may be
Transportation exclusion permitted for Benefit Plans effective March 1 required.
Fringe Benefits qualified parking benefits sunsets
($230 for 2009 and $230 December 31, Administration
for 2010) shall also apply 2010. changes.
to vanpooling and transit
pass benefits.
COBRA ARRA-compliant COBRA All health plans sub- February 17, Amendment/SMM
Changes under election notices; COBRA ject to COBRA (other 2009 effective may be required.
the American subsidy calculations; than FSAs). date April 18
Recovery and refunds/credits for overpay- notice deadlines; Administration
Reinvestment ments of March and April sunsets December changes.
Act of 2009 COBRA premiums; proper 31, 2010
(“ARRA”) representation of creditable
coverage period of HIPAA Proposed legisla-
certificates; management of tion (HR 3930)
notice and waiver process; may extend subsidy
extension of COBRA period sunset.
for PBGC individuals and
TAA-eligible individuals.
22 • The Self-Insurer
©
/ January 2010
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