Sponsors: Medicare & Employer Health Coverage - a ... · Webinar Presenters PRESENTER Lawrence (Larry) Grudzien, JD, LLM is an attorney practicing exclusively in the field of employee

Copyright 2020 – Not to be reproduced without express permission of benefitexpress

Webinar for Plan Sponsors: Medicare &

Employer Health Coverage -

a Coordination Conversation

Webinar Presenters

PRESENTER

Lawrence (Larry) Grudzien, JD, LLM is an attorney

practicing exclusively in the field of employee benefits.

MODERATOR

Julia Goebel is Chief Marketing Officer, benefitexpress

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Case Study: Restaurant/Retailer

~65,000

employees

~18,000

eligible

Restaurants

Benefits Enrollment

Technology &

Administration

Decision

Support

ACA & Related

Compliance

Reimbursement Solutions

(HSA, FSA, HRA)

COBRA &

Direct Bill

Initially Contracted

Consideration

Solutions Added

Industry Size

Client Needs

Situation Overview

▪ Client required significant Benefits Administration

technology enhancements compared to its current

solution set via legacy provider of 13 years

– Partnered with herronpalmer to assess Benefits

Admin strategy and review marketplace

▪ Benefitexpress leveraged strong industry reputation

with competitive pricing to win business in late 2018

▪ Upgrades to enrollment website (including customizations)

▪ On-shore call center for employee service

▪ Billing arrear administration for variable-hour employees

▪ Improved reporting and transparency


4

Case Study: Healthcare System

~26,000

employeesHealthcare

▪ Consolidation of administration across multiple health entities

▪ State-of-the-art technology

▪ Support for PeopleSoft and UltiPro

▪ Introduction of closed-loop payroll and capture of retro

payroll deductions

▪ Following hospital system merger, broker (Conner

Strong) was assigned to find a BenAdmin solution that

could support the consolidated entities and help

harmonize plan design, vendors, policies, and cost

▪ Benefitexpress invited to compete for business based on

its strong relationship with Conner Strong

▪ Benefitexpress was selected over incumbents (bswift and

Fidelity) in 2018

Reimbursement Solutions

(HSA, FSA, HRA)Initially Contracted

Consideration

Solutions Added

Industry Size

Client Needs

Situation Overview

Benefits Enrollment

Technology &

Administration

Decision

Support

ACA & Related

ComplianceCOBRA &

Direct Bill


5

Agenda

• Medicare Secondary Payer Rules

• Medicare Part D

• COBRA

• Other areas


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PAYER RULESMEDICARE SECONDARY


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Medicare Secondary Payer Rules

Can an employer in any way encourage active employees to elect out of employer

sponsored health coverage when they are eligible for Medicare?

• No. The Medicare Secondary Payer statute prohibits a group health plan from “taking

into account” the Medicare entitlement of an active employees or family members if

such employees are still considered in “current employment status.”

• Employers are prohibited from discouraging employees from enrolling in their group

health plan or from offering “financial or other incentive for an individual entitled to

Medicare” not to enroll (or to terminate enrollment) under” a group health plan that

would otherwise be a primary plan.

• The above prohibition does not apply to employers with less than 20 employees

for each working day in at least 20 weeks in either the current or the preceding

calendar year.

• This test must be run at the time the individual receives the services for which

Medicare benefits are claimed.


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What does “current employment status” mean?

• A person has current employment status

if he or she is actively working as an employee,

is the employer (including a self-employed person),

or is associated with the employer in

a business relationship.


9


Can an employer drop employees or dependents who become disabled from

employer sponsored health coverage when they become eligible for Medicare if

such employees are considered in “current employment status”?

• No. The Medicare Secondary Payer statute prohibits a group health plan from “taking

into account” the Medicare entitlement of disabled employees or a family member .

• An otherwise covered individual who isn’t actively working is nevertheless considered

to be in “current employment status” if he or she:

- is receiving disability benefits from an employer for up to six months; or

- retains employment rights in the industry, hasn’t had his or her employment

terminated by the employer, isn’t receiving disability benefits from an employer

for more than six months or from Social Security, and has group health coverage

other than COBRA coverage (whether or the individual receives pay).


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• This prohibition does not apply

to employers with less than 100

employees on a typical business day

during the previous calendar year.

• This means that the employer must

have 100 or more employees, whether

full-time or part-time, on at least 50%

of its regular business days during the

previous calendar year.


11


Who is considered a "disabled

individual" under the MSP rules?

• Disabled individuals generally are those

individuals who are under age 65 and

who have been entitled to Social Security

disability benefits for 24 months.

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Which employees are counted in determining the number of

employees for the “small employer exception”?

• In counting an employer’s employees for purposes of the small employer exceptions,

the following rules apply:

⁃ Leased employees must be counted if they would be counted as employees

under code § 414(n);

⁃ All of the employees of the members of an “affiliated service group” (as defined in

code § 414(m)) must be counted as if they were employees of a single employer; and

⁃ All of the employers that are considered to be a “single employer” under

code § 52(a) or 52(b) must be treated as a single employer.


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What does it mean to “take into account” Medicare entitlement?

• Under the MSP statute, a group health plan may not take into account:

⁃ the age-based Medicare entitlement of an individual (or the individual’s spouse) who

is covered under the plan by virtue of the individual’s current employment status ;or

⁃ the disability-based Medicare entitlement of an individual (or the individual’s family

member) who is covered under the plan by virtue of the individual’s current

employment status.

• A plan must provide a current employee or a current employee’s spouse who is age 65

or older with the same benefits, under the same conditions, as are provided to

employees and spouses who are under age 65.


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Examples of employer or insurer actions that constitute an impermissible “taking into

account” are provided in the regulations and include the following:

• Failure to pay primary benefits;

• Offering coverage that is secondary to Medicare to individuals entitled to Medicare;

• Terminating coverage because the individual has become entitled to Medicare, except

as permitted under COBRA;

• Denying or terminating coverage because an individual is entitled to Medicare on the

basis of disability without denying or terminating coverage for similarly situated

individuals who are not entitled to Medicare on the basis of disability;

• Imposing limitations on benefits for a Medicare-entitled individual that

don’t apply to others enrolled in the plan;


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• Charging a Medicare-entitled individual higher premiums;

• Requiring a Medicare-entitled individual to wait longer for coverage to begin;

• Paying providers and suppliers less for services furnished to a Medicare beneficiary than

for the same services furnished to an enrollee who is not entitled to Medicare;

• Providing misleading or incomplete information that would have the effect of inducing a

Medicare-entitled individual to reject the employer plan, thereby making Medicare the

primary payer;

• Including in its health insurance cards, claims forms, or brochures distributed to

beneficiaries, providers, and suppliers' instructions to bill Medicare first for services

furnished to Medicare beneficiaries without stipulating that such an action may be taken

only when Medicare is the primary payer; and

• Refusing to enroll an individual for whom Medicare would be the secondary payer, when

enrollment is available to similarly situated individuals for whom Medicare would not be

the secondary payer.


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What are considered “incentives”

under the rules?

• Employers are prohibited from discouraging

employees from enrolling in their group health

plans or from offering any “financial or other

incentive” for an individual entitled to

Medicare “not to enroll (or to terminate

enrollment) under” a group health plan that

would otherwise be a primary plan.

• The prohibition applies “even if the payments

or benefits are offered to all other individuals

who are eligible for coverage under the plan.”


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Can a Medicare or Medigap premiums be reimbursed

by an employer for an active employees?

• Generally no, but there are three exceptions:

⁃ A small employer follows the rules under Notice 2015-17,

⁃ A small employer can adopt a Qualified Small Employer HRA, or

⁃ A large or small employer can adopt an Individual coverage HRA in 2020 or after.

• If an employer offers to reimburse Medicare premiums for its active employees,

it creates an employer payment plan because Medicare is not considered

employer group coverage.


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Exception under IRS Notice 2015-17:

An HRA can pay for or reimburses Medicare Part B or Part D premiums if its is integrated

with another group health plan offered by the employer for purposes of the annual dollar

limit prohibition and the preventive services requirements and meets the following rules:

• The employer offers a group health plan (other than the employer payment plan)

to the employee that does not consist solely of excepted benefits and offers

coverage providing minimum value;

• The employee participating in the employer payment plan is

actually enrolled in Medicare parts A and B;

• The HRA is available only to employees who are enrolled in

Medicare part A and part B or part D; and

• The employer payment plan is limited to reimbursement of Medicare part B or part D

premiums and excepted benefits, including Medigap premiums.


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Exception under IRS Notice 2015-17:

• Note that to the extent such an arrangement is available to active employees,

it may be subject to restrictions under other laws such as the Medicare secondary

payer provisions.

• An employer payment plan that has fewer than two participants who are current

employees (for example, a retiree-only plan) on the first day of the plan year is

not subject to the market reforms and, therefore, integration is not necessary

to satisfy the market reforms.


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Exception under a QSEHRA:

• Only available for employers who are not ALEs who do not sponsor a group health plan

• Plan must meet eligibility and same terms requirements

• Employers with 20 or more employees are subject to the

Medicare Secondary Payer Rules.


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Exception under the ICHRA:

• Can be used by both large and small employers.

• Eligible employees must not be eligible for group

medical coverage.

• Cannot target just employees eligible for Medicare.

• Must meet group and benefit requirement.

• To avoid violation of the Medicare Secondary

Payer rules, the employee must be able to be

reimbursed for other medical expenses other

than Medicare premiums.


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Do any special rules apply if an employer participates in multiemployer

or multiple employer plan?

• Yes, With respect to age-based Medicare entitlement, the MSP statute provides that if

at least one of the employers in the plan has 20 or more employees, then the group

health plan will be subject to the MSP rules.

• However, the plan may elect not to have the age-based MSP rules apply to employees

of employers in the plan that have fewer than 20 employees.

• A different rule applies to multiemployer and multiple employer plans under the

disability-based Medicare entitlement provisions.

• Under these provisions, if any one employer in the plan employed 100 or more

employees on at least 50% of its regular business days during the previous calendar

year, the plan will be considered to be a large group health plan subject to the MSP

rules for disabled employees.


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Are there any special rules for Medicare eligibility

or entitlement based on ESRD?

• Yes, a group health plan (including a retiree medical plan) cannot take into account an

individual’s ESRD-based Medicare eligibility or entitlement for the first 30 months of

such eligibility or entitlement.

• Medicare generally must be the secondary payer for the first 30 months of an ESRD

patient’s Medicare eligibility or entitlement (and will be primary thereafter.)

• A plan may not otherwise differentiate in benefits provided under the plan between

ESRD patients and other individuals covered under the plan based on the existence of

ESRD, the need for renal dialysis, or in any other manner.


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• These prohibitions apply regardless of whether the individual has

coverage by virtue of current employment status, and there is no

exception for small employers.

• Medicare will remain primary, however, for an individual who was

entitled to Medicare due to age or disability on a primary basis at the

time he or she becomes eligible for ESRD-based Medicare.


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Does an employer’s prescription drug plan have to be coordinated with

employee’s Medicare Part D drug plan?

• Yes. The MSP rules are triggered when individuals

who are enrolled in group health plans offering

prescription drug coverage also enroll

in Part D plans.

• Part D plans and group health plans are

generally required to comply with MSP laws

and any other federal and state laws

establishing payers of last resort.


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Can an employee elect out of employer

coverage on their own and elect Medicare?

• There is nothing preventing an employee

electing out of employer coverage

on his or her own.


27


Are Health FSAs, HRAs Archer MSAs or HSAs subject to these rules?

• Health FSAs, HSAs, and Archer MSAs are not subject to the MSP Rules;

• HRAs are subject to the MSP Rules.

• ICHRAs have special exception.

• CMS has indicated that for MSP purposes, health FSAs (as well as HSAs

and Archer MSAs) aren’t group health plans and aren’t subject to being

a primary payer under MSP laws.

• HRAs, however, are group health plans subject to the MSP rules—information

about HRAs should be reported to CMS in the same manner as group health

plan information is reported.


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If an employee continues to be covered under an employer provided health

coverage, will he or she be penalized when he or she decides to elect Medicare?

• No It is extremely important that an employee enrolls in Medicare during his or her initial

enrollment period.

• If an employee does not, he or she will be subject to late charges or a premium surcharge

• The Part B premium goes up 10 percent for each 12-month period the employee was

eligible but does not enroll. The increase in the Part A premium (if the employee has to pay

a premium) is 10 percent no matter how late the employee enrolls.

• The employee may enroll in Part B or premium Part A at any time he or she is covered

under another group health plan.

• However, the employee may also choose to wait and enroll during a special

eight-month period. This special period would start with the month the employee or

his or her spouse stops working or when he or she is no longer covered by the

employer plan, whichever comes first.


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Once a retiree becomes eligible for Medicare, can retiree coverage

be coordinated with Medicare?

• Yes, EEOC provided final regulations that allows employers that provide retiree

health benefits to continue the longstanding practice of coordinating those benefits

with Medicare (or comparable state health benefits) without violating the

Age Discrimination in Employment Act (ADEA).

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Are there any penalties if an employer violates these

Medicare Secondary Payer rules?

• The federal government and Medicare recipients are authorized to recover double

damages from group health care plans that treat Medicare as the primary payer in

violation of the rules.

• Violation of the financial incentives prohibition is subject to a civil money penalty of up

to $5,000 for each violation.

• Code Section 5000 also imposes an excise tax of 25% of expenses on all employers,

other than certain governmental entities, or employee organizations whose group

health care plans fail to comply with the Medicare secondary payer rules. Employers or

employee organizations may appeal HCFA determinations of a failure to comply with

Code Section 5000.

• The government has three years to collect health care payments that were wrongly paid

by Medicare from the primary party.


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Is there any reporting requirements under the Medicare

Secondary Payer Rules?

• Yes Under Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of

2007 (MMSEA), new mandatory reporting requirements was added for group

health plans and for non-group health plan arrangements (liability insurance

including self-insurance, no-fault insurance and workers' compensation).


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Who is required to report the mandatory reporting

information to CMS?

• The responsibility for reporting information to help identify whether a group health

plan is (or has been) a primary plan to Medicare falls upon the “entity serving as an

insurer or third party administrator for a group health plan...and, in the case of a group

health plan that is self-insured and self-administered, a plan administrator or fiduciary.”

• CMS refers to entities that are responsible for complying with the reporting

requirements under Section 111 as “responsible reporting entities” (RREs).


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What plans are subject to the Section 111 reporting requirements?

• Many types of group health plans are subject to the MSP rules in general.

• Health FSAs and HSAs are not, but HRAs are.

⁃ No reporting if annual benefits are less than $5,000.

⁃ ICHRAs can be subject.


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What information should be reported to CMS?

• CMS must be provided information regarding all individuals meeting the definition of

an “active covered individual.”

• In general, an active covered individual is someone who may be Medicare eligible and

currently is employed, or the spouse or other family member of a worker who is

covered by the employed individual's group health plan and who may be eligible for

Medicare and for whom Medicare would be secondary payer.


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For mandatory reporting purposes, CMS has defined “active covered individuals” in

its User Guide to include all individuals covered in the group health plan who—

• are ages 45 through age 64 with coverage based on their own or

a family member’s current employment status;

• are age 65 and older with coverage based on their own or a spouse’s

current employment status;

• have been receiving kidney dialysis or have received a kidney transplant,

regardless of their own or a family member's current employment status; or

• are under age 45, are known to be entitled to Medicare, and have coverage

in the plan based on their own or a family member’s current employment status

regardless of their age.


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How and when should information be reported to CMS?

• Information may be submitted only through an electronic process under which new

group health plan RREs will register online through a secure website using an interactive

web portal designed for that purpose.

• Once data has been submitted, CMS will work with the RREs to set up the data

reporting and response process, and it will use the information to ensure that payment

is made in the proper order and to pursue recovery activities.

• CMS has indicated that RREs must submit information on a quarterly basis


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What the penalties for failure to comply with Section 111

reporting requirements?

• Entities that fail to comply with the MMSEA Section 111 reporting requirements are

subject to a civil monetary penalty of $1,000 for each day of noncompliance for each

individual for which information should have been submitted.

• This fine is in addition to any other penalties prescribed by law and any potential claims

under the MSP regulations (e.g., a claim by Medicare that the group health plan should

have paid primary to Medicare).


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PART DMEDICARE


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Medicare Part D

For those employee who are eligible for Medicare Part D benefits,

what disclosure must an employer provide them?

• Each year before October 15th, an employer

must provide a notice to those eligible employees

whether its prescription drug plan is either

“creditable” or “noncreditable.”


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Medicare Part D

In what other situations must the notice be distributed?

• Prior to an individual's initial enrollment period (IEP) for part D—the timing of the IEP

varies according to several factors;

• Prior to the effective date of coverage for any part D eligible individual that enrolls in the

employer's prescription drug coverage—the timing of the effective date of coverage

varies for each individual;

• Whenever the employer no longer offers prescription drug coverage or changes it so

that it is no longer creditable or becomes creditable—the timing of a change in coverage

generally varies according to the employer's actions; and

• Upon request by the part D eligible individual—the timing of a request varies according

to the individual's actions.


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Medicare Part D

Why does an employer have to give this notice?

• If an employer’s prescription drug coverage is not considered “creditable,” the employee

may be subject to a late enrollment penalty.

• A late enrollment penalty may apply after experiencing a lapse in creditable prescription

drug coverage for any continuous period of 63 days or longer at any time after the end

of the individual’s IEP for Part D.

• The penalty amount will be the base beneficiary premiums that would otherwise apply

will be increased by the greater of (1) an amount that CMS determines is actuarially

sound for each uncovered month in the same continuous period of eligibility; or (2) 1%

of the base beneficiary premium for each uncovered month in the period.


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Medicare Part D

Are there any penalties if an employer either does not provide the

notice or provides an incorrect notice to employees?

• Neither the law nor the regulations provide mechanisms for CMS to enforce

penalties or other sanctions against employers that fail to comply with the

disclosure requirements, other than those claiming the retiree drug subsidy.

• However, employers that don’t comply with such requirements are likely

to encounter adverse employee relations issues.


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Medicare Part D

Are there any other disclosures that an employer must make under

Medicare Part D?

• Group health plan sponsors must also notify CMS about creditable coverage status.

• The Disclosure to CMS Form that must be used to disclose to CMS whether the group

health plan coverage is creditable must be completed and sent electronically through the

CMS website (hard copies are not generally allowed).

• There is one exception, however.

• Entities without Internet access can request that copies of the Disclosure to CMS Form be

faxed to them, presumably for completion and return to CMS on hard copy

• Notice must be given annually within 60 days after the end of the plan year.


44

MEDICARECOBRA &


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COBRA

When can the entitlement of Medicare

terminate COBRA coverage?

• When any qualified beneficiary (including the

covered employee) first becomes entitled to

Medicare after electing COBRA coverage, his

or her COBRA coverage can be terminated

early (i.e., before the end of the maximum

coverage period).

• This rule does not, however, affect the COBRA

rights of other qualified beneficiaries in a family

unit who are not entitled to Medicare (for

example, the spouse and dependent children

of a Medicare-entitled former employee).


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COBRA

When does Entitlement to Medicare extend the

period of COBRA coverage?

• When a covered employee’s qualifying event (i.e., a termination of employment or

reduction of hours) occurs within the 18-month period after the employee becomes

entitled to Medicare, the employee’s spouse and dependent children (but not the

employee) become entitled to COBRA coverage for a maximum period that ends 36

months after the covered employee becomes entitled to Medicare.

• The covered employee remains entitled to a basic maximum period that ends 18 months

after the termination of employment or reduction of hours.


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COBRA

Does the entitlement to Medicare before electing COBRA

terminate COBRA coverage?

• No. When any qualified beneficiary (including the covered employee)

is entitled to Medicare before electing COBRA, he or she still has the right

to elect COBRA coverage.

• The COBRA offer cannot be withheld because of Medicare entitlement.

• And this coverage may not be terminated early because of the

Medicare entitlement.


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COBRA

Is entitlement to Medicare ever a first qualifying event

to trigger COBRA?

• The covered employee’s entitlement to Medicare is one of COBRA’s

listed qualifying events.

• It is a qualifying event only for the spouse and dependent children,

not for the covered employee,

• But because Medicare entitlement will only infrequently cause a loss of coverage

under a group health plan, it will rarely be a COBRA qualifying event.

• It is permissible under the MSP rules for Medicare entitlement to cause a loss of

coverage for covered retired employees (and their spouses and dependent children).


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COBRA

Will enrolling in Medicare preserve an employee’s special enrollment

rights under Medicare?

• COBRA coverage is not considered a group health plan

based upon current employment.

• Individuals who, in order to retain their COBRA coverage,

do not enroll in Medicare when first eligible will not have

special enrollment rights under Medicare and may expect

to pay more for Medicare when COBRA coverage ends.


50

COBRA

Must a plan still offer COBRA coverage to retirees when alternative

retiree coverage is offered?

• Yes. Alternative retiree coverage might be offered under the plan covering active

employees, or it might be offered under a separate retiree plan.

• In either case, the employer cannot avoid its obligation to offer COBRA coverage in

connection with the employee’s retirement simply by providing alternative retiree

coverage.


51

COBRA

Must a plan offer COBRA to

retirees when alternative

retiree coverage expires?

• The regulations make it clear that if

a retiree (and his or her family) are

offered but do not elect COBRA

and instead choose alternative

retiree coverage available for a

fixed period of time, no COBRA

election must be offered when the

retiree coverage expires.

• This result would be the same

whether retiree coverage is offered

under a combined retiree/active

plan or under a retiree-only plan.


52 52

AREASOTHER


53

HSAs

When is an individual no longer eligible to

contribute to an HSA?

• Code § 223(b)(7) reads as follows: “Medicare eligible individuals. The [contribution limit]

under this subsection for any month with respect to an individual shall be zero for the

first month such individual is entitled to benefits under title XVIII of the Social Security

Act and for each month thereafter.

• An individual can become entitled to Medicare benefits (under Title XVIII of the Social

Security Act) for three reasons: age, disability, or end-stage renal disease (ESRD).

• Entitlement to Medicare Part A is automatic for some individuals (i.e., a separate

application is not required) because they have already applied for and are receiving

Social Security or Railroad Retirement Act benefits.

• Other individuals must file an application in order to become entitled to Part A benefits.


54

HSAs

Are there any special rules if an employee enrolls in

Medicare after age 65?

• In Information Letter 2016-0082, the IRS indicated that health savings account (HSA)

holders cannot make contributions for months of retroactive Medicare coverage.

• This because Medicare coverage typically begins with the month an individual

turns age 65, but the actual commencement date depends on when the individual

applies for Medicare (or Social Security or Railroad Retirement benefits that trigger

Medicare coverage).

• Individuals who delay applying for free Medicare Part A are covered retroactively to the

month they attained age 65 or for six months, whichever is less.

• The IRS explained that the Code sets a zero-contribution limit for months of Medicare

coverage and that rule has no exceptions, so months of retroactive Medicare must also

reduce HSA contributions.


55

HSAs (cont.)

Are there any special rules if an employee enrolls in

Medicare after age 65?

• As a result, an HSA account holder who overcontributes because of retroactive Medicare

coverage can be subject to a subject to a 6% excise tax under Code Section 4973, unless

the excess contribution and earnings are withdrawn by the federal tax return filing

deadline (including extensions) for the contribution year. That is April 15, 2020 for 2019.

• Timely withdrawals of excess contributions are not subject to the 20% additional tax for

non-medical distributions.

• The additional income tax also does not apply to distributions made after an HSA

account holder attains age 65, so even if the excess is not timely withdrawn, it can be

withdrawn later without incurring this additional tax.


56

HSAs

Can an HSA be used to reimburse an individual

for Medicare premiums?

• Yes. Deductible health insurance premiums (other than for a Medicare supplemental

policy) for an account holder who is age 65 or older can be paid or reimbursed through

an HSA on a tax-free basis, including medical premiums for an employer’s insured or

self-insured retiree health coverage.

• When premiums for Medicare Part A (hospital and inpatient services), Part B (physician

and outpatient services), Part C (Medicare HMO and PPO plans), or Part D (prescription

drugs) are deducted from Social Security benefit payments received by an account

holder who is age 65 or older, he or she can take a tax-free HSA distribution equal to

the Medicare premium deduction.

• HSAs generally cannot be used by retired account holders for their health insurance

premiums prior to age 65—with the exception of COBRA coverage (or premiums paid

while receiving unemployment.


57

HIPAA

Is Medicare coverage considered

“creditable coverage” for

HIPAA purposes?

• Medicare is subject to HIPAA’s certification

requirements under the PHSA and thus

count as creditable coverage, but they are

not otherwise subject to HIPAA’s portability

provisions (e.g., PCEs, special enrollments,

and nondiscrimination) because they do

not constitute “group health plan” coverage

as defined in the PHSA, ERISA, or the Code.


58

QUESTIONS?


Julia Goebel

Chief Marketing Officer

[email protected]

Attorney at Law

[email protected]

Larry Grudzien

Contact information

Documents

Sponsors: Medicare & Employer Health Coverage - a ... · Webinar Presenters PRESENTER Lawrence (Larry) Grudzien, JD, LLM is an attorney practicing exclusively in the field of employee