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VEBA Service Groupa Division of Gallagher Benefit Services, Inc.
WASBO PPR Presentation
Presented by: Brian Riehs ▪ February 4, 2014
Introduction
Plan participation confirmation Contribution instructions Plan documents Plan design change Premium Tax Credit Administrative reminders General plan reminders Common funding methods See you at WASBO!
12/20 was a busy email day!
Plan participation confirmation Contribution instructions Plan documents Premium Tax Credit
Plan Participation Confirmation
New Employer Adoption Agreement
Plan Participation Confirmation form
Contributions will not be processed without first receiving either one of the above
Contribution Instructions
“001” for Standard HRA “002” for Post-separation HRA New Contribution Template Old template no longer accepted
Plan Documents
Standard HRA Plan (Full Benefits) Standard HRA Plan (Pre-Medicare
Limited-Scope) Post-separation HRA Plan (Full
Benefits) Post-separation HRA Plan (Pre-
Medicare Limited-Scope)
Plan Design Change
Standard HRA Plan For employees who are eligible to
enroll in your qualified group health plan and
Are enrolled in or covered by your plan; or Attest that they are enrolled in or covered
by another qualified group health plan
Reimburses all qualified health care expenses (in-service and post-separation)
Plan Design Change
Post-separation HRA Plan For all eligible employees,
including those who do not qualify for Standard HRA Plan contributions
Reimburses all qualified health care expenses (post-separation only)
Claims eligibility suspended for re-hires during such re-employment period
Plan Design Change
Pre-Medicare Limited-Scope (law requires separate plan document)
Available option for Standard and Post-separation HRA participants who purchase coverage through an exchange and want to become eligible for the Premium Tax Credit
Irrevocable election until Medicare eligibility
Reimburses certain dental, vision, and long-term care expenses and premiums only
Premium Tax Credit
If a participant (or a family member) purchases coverage through a marketplace exchange and wants to qualify for the Premium Tax Credit first need to use up, limit, or waive their HRA (VEBA) benefits
Premiums for exchange coverage may be reimbursed; premiums subsidized by the Premium Tax Credit cannot be reimbursed
More information www.irs.gov/uac/The-Premium-Tax-Credit Facts About Premium Tax Credit handout
available online Participants received information in January 2014
Participant News
Administrative Reminders
No Form W-2 reporting Use new contribution template Use updated Memorandum of
Understanding and Employer Policy language samples
Submit Plan Design Change Form to report new participating groups, funding method changes/additions, etc.
Fully complete EMPLOYER shaded box when submitting Enrollment Forms
Administrative Reminders
Don’t submit negative contributions; request a Mistake of Fact Notification form to correct contribution overpayments
Don’t discriminate; change percent-of-pay contributions to a uniform, flat-dollar amount
Operate under the 1990 “all or none” IRS private letter ruling; it is more conservative than the 1993 “excess sick leave forfeiture” ruling
Avoid small groups for VEBA purposes; voting groups should have a least five members
General Plan Reminders
New investment options effective October 2013
PCORI fee (currently $2/year per participant) is required by federal health care reform; it is not an administrative fee
Legally-married, same-sex spouses now covered
Young adult children covered through end of calendar year in which they turn age 26
General Plan Reminders
HSA contribution eligibility requires limited-purpose HRA (VEBA) coverage
If still working and on Medicare, VEBA pays first (unless limited-purpose VEBA coverage is elected)
Participants who purchase medical coverage through a marketplace exchange and want to qualify for the Premium Tax Credit may need to first use up, limit, or waive their VEBA benefits
Common Funding Methods
Mandatory employee contributions Sick leave cash out (retirement and
annual) Vacation, personal, other leave cash
outs Part or all of future pay raise or COLA Contribution after electing lower-cost
medical plan
See you at WASBO!
April 23-25 Attend our presentations,
including VEBA Basics on April 24 @ 1:20 p.m.
Stop by our booth!
Questions?
