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© MERCER 2019 0 Brian Kearney Denver, CO Amy Knieriem Washington, DC Geoff Manville Washington, DC Katharine Marshall Chapel Hill, NC Dorian Z. Smith New York, NY WASHINGTON UPDATE Dec. 12, 2019 HEALTH WEALTH CAREER LAW & POLICY GROUP

Washington Update Webinar Deck – July 2019 (PPT)€¦ · 2019-12-12  · –Requires more transparency for PBM services, bans “spread pricing,” mandates that 100% of rebates

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Page 1: Washington Update Webinar Deck – July 2019 (PPT)€¦ · 2019-12-12  · –Requires more transparency for PBM services, bans “spread pricing,” mandates that 100% of rebates

© MERCER 2019 0

Brian Kearney

Denver, CO

Amy Knieriem

Washington, DC

Geoff Manville

Washington, DC

Katharine Marshall

Chapel Hill, NC

Dorian Z. Smith

New York, NY

WA S H I N G T O N U P D AT E

Dec. 12, 2019

H E A L T H W E A L T H C A R E E R

L A W & P O L I C Y G R O U P

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© MERCER 2019 1

T O D A Y ’ S S P E A K E R S

KATHARINE MARSHALL

Chapel Hill, NC

GEOFF MANVILLE

Washington, DC

AMY KNIERIEM

Washington, DCBRIAN KEARNEY

Denver, CO

DORIAN Z. SMITH

New York, NY

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© MERCER 2019 2

A G E N D A

2

1

3 EXECUTIVE COMPENSATION

HEALTH & BENEFITS

WEALTH

4 MERCER RESOURCES

CLOSING COMMENTS5

6 QUESTIONS

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© MERCER 2019 3© MERCER 2019 3

HEALTH & BENEFITS

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L E G I S L A T I V E D E V E L O P M E N T S

B I G P O L I C Y C H A N G E S D E F Y C O N S E N S U S

Progressive Democrats push

Medicare for all.

Sens. Bernie Sanders and Elizabeth

Warren urge enrolling all US residents in

a single plan and eliminating employer-

based coverage.

Bipartisan deals are possible

on targeted reforms aimed at

surprise bills, drug prices,

transparency and the

Cadillac tax.

Some reforms could find a home

in must-pass, year-end legislation.

Republicans have little

agreement on what’s next if

ACA is struck down by courts.

Republicans say they would restore

protections for preexisting conditions,

but could party coalesce around a

replacement plan? Could the parties

agree on a stop-gap plan?

Moderate Democrats want to

expand Medicare and strengthen

the Affordable Care Act (ACA).

Centrists propose Medicare-based

public plan option in individual market

and Medicare buy-in for older workers.

ACA proposals would increase and

expand subsidies, seek greater

enrollment and fix “family glitch.”

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© MERCER 2019 5

• Senate, House lawmakers strike bipartisan deal on broad healthcare package.

– Next steps on surprise billing unclear as lead House tax writers assert jurisdiction.

• Deal protects patients from “surprise” bills from out-of-network providers.

– Resolves payment disputes with median in-network rate, but providers could go to

arbitration for payments over $750.

– Party initiating arbitration couldn’t bring similar claim for 90 days.

– Air ambulance bills addressed, arbitration allowed for bills over $25,000.

• Transparency, competition provisions aimed at lowering overall costs.

– Bans gag clauses, anti-competitive terms in provider network agreements.

– Requires more transparency for PBM services, bans “spread pricing,” mandates that

100% of rebates be passed through to employers.

– Encourages state all-payer claims database with federal standard for ERISA plans.

• Proposals to lower drug prices encourage more generic, biological products.

L E G I S L A T I V E D E V E L O P M E N T S

D E A L O N S U R P R I S E B I L L S , O T H E R H E A L T H I T E M S

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• Sweeping House, Senate proposals face uncertain future.

– House Democrats’ Lower Drug Costs Now Act (HR 3) set for House vote.

- Directs HHS to negotiate directly with drug makers for certain drugs.

- Effectively caps price hikes of Medicare drugs at general inflation.

– House GOP bill (HR 19) bundles targeted reforms passed by committees.

– Bipartisan Senate Finance Committee bill (S 2543) undergoing changes.

- Overhauls Part D and cuts seniors’ expenses, also seeks to cap price increases.

- White House support could provide momentum.

• More modest, bipartisan reforms have best chance of clearing Congress.

– Array of bills would remove barriers for generic drugs.

– More PBM transparency, rebate reforms also in play.

– Proposals raise revenue needed to pay for other health policy priorities.

L E G I S L A T I V E D E V E L O P M E N T S

P A R T I E S S P A R O V E R B I G D R U G - P R I C I N G R E F O R M S

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• Broad coalition urging Senate to repeal ACA Cadillac tax.

– House voted 419-6 for repeal in July (HR 748) but did not include “pay-fors” to

offset projected revenue loss of $197 billion over 10 years.

– Companion Senate bill (S 684) has more than 60 bipartisan co-sponsors.

• Legislation would repeal (HR 2447) and/or suspend (HR 1398) the health

insurance (HIT) tax set for reinstatement in 2020.

• PCORI fee could be re-authorized.

– House-Senate negotiators considering a ten-year extension with changes to

underlying program sought by employers.

• Senators trying to revive expiring Health Coverage Tax Credit.

– Credit pays 72.5% of cost of health insurance premiums for workers who

receive trade adjustment assistance or benefits from the PBGC.

L E G I S L A T I V E D E V E L O P M E N T S

A C T I O N P O S S I B L E O N C A D I L L A C T A X , P C O R I F E E

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R E G U L A T O R Y D E V E L O P M E N T S

A P P E A L S T I L L U N D E R W A Y O V E R A C A ’ S V A L I D I T Y

Lower Court Finds ACA Invalid

A federal district court invalidated the

ACA but later stayed the ruling (Texas

v. United States (N.D. Tex. Dec. 30,

2018)).

Agreeing with GOP attorneys general

from 20 states, the court held:

• The individual mandate is

unconstitutional because it isn't a

tax anymore ($0 penalty in 2019

due to tax reform).

• The entire ACA must be struck

down because the individual

mandate is integral to the law.

Appeal Hearing Held

Fifth Circuit judges asked questions

about tough issues:

• Would law look different in various

states?

• If less than full ACA is struck, what

provisions would government want to

keep?

• What if the entire ACA is struck?

Current status of the ACA

No immediate effect on the ACA, but

the case may eventually reach the US

Supreme Court.

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R E G U L A T O R Y D E V E L O P M E N T S

O N G O I N G A C A E S R E N F O R C E M E N T, R E P O R T I N G

No indication IRS enforcement will slow down.

• Applicable large employers (ALEs) remain subject to potential ESR assessments for

failing to offer affordable, minimum-value coverage to full-time employees.

• IRS continues to issue proposed assessments (Letter 226-J).

• Some employers have received IRS Letter 5699 about missing filings.

2020 marks the fifth year of ACA reporting.

• Deadline for furnishing individuals 2019 Form 1095-B/1095-C extended (from Jan. 31

to March 2).

• IRS filing deadline remains the same (Feb. 28 for paper, March 31 for electronic).

• Good faith compliance relief extended for incorrect or incomplete reports.

New relief for MEC reporters from penalty for failure to furnish Form 1095-B to individuals if

certain conditions are met.

• Still required to file with IRS.

• Relief generally not available for self-insured ALEs.

• No similar relief for ESR reporting required of ALEs.

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R E G U L A T O R Y D E V E L O P M E N T S

E V O L U T I O N O F H R A s

Pre-ACA

Employers can provide tax-

free employer-funded

accounts to employees to use

for medical expenses,

including premium

reimbursement.

ACA

• HRAs are group health plans

(GHPs).

• Stand-alone HRAs do not meet

standards for GHPs.

• HRAs for active employees

must be integrated with GHP

(retiree-only HRAs can be

offered stand-alone).

Oct. 2017 Executive Order

• Executive Order instructs

agencies (DOL/IRS/HHS) to

find new ways to increase

health coverage access.

• Calls on agencies to expand

use and flexibility of HRAs.

Oct. 2018 Proposed Regulations and IRS Notice

2018-88

• Allowing HRAs to be integrated with individual

coverage.

• Providing employer shared responsibility (ESR)

guidance for individual coverage HRAs.

• Confirming individual coverage HRA is MEC

• Proposing location safe harbor for affordability

determination

• Proposing that if HRA is affordable, then it meets

minimum value (MV) requirements

June 2019 Final Rules

Allows HRAs to be

integrated with

individual coverage and

Medicare.

• Employers can also

offer new excepted

benefit HRA.

• Effective Jan. 2020

Sept. 2019 Proposed Rules

Application of ESR provisions

and certain nondiscrimination

rules to HRAs integrated with

individual coverage or

Medicare, and certain safe

harbors.

• Comments until Dec. 30,

2019.

2020

Final ESR

rules?

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R E G U L A T O R Y D E V E L O P M E N T S

D R U G C O U P O N S A N D O U T - O F - P O C K E T C O S T S

T E M P O R A R Y N O N - E N F O R C E M E N T P O L I C Y

New Rule From 2020 Notice of Benefit and Payment Parameters

• Amounts paid toward cost-sharing using any form of direct drug manufacturer support (e.g., a coupon

or drug copay card) for brand drugs are not required to be counted toward a health plan’s annual out-

of-pocket maximums where a generic drug is available and medically appropriate.

• Effective for plans beginning on or after Jan. 1, 2020.

Does the value of direct drug manufacturer support for brand drugs (particularly specialty

drugs) have to be counted toward OOPM where a generic drug is not available?

Agency FAQ and Non-Enforcement Policy

• DOL/IRS/HHS issued FAQ saying they won’t enforce the 2020 rule until further rules are published,

likely the Notice of Benefit and Payment Parameters for 2021 expected in January or February 2020.

• Acknowledged conflict between compliance with the new rule and compliance with existing HSA

eligibility rule that requires the exclusion of discounts when calculating out-of-pocket costs towards an

HDHP deductible.

Crediting drug’s undiscounted cost toward OOP limits shifts costs from participants

to the plan. Copay accumulators or accumulator adjustment programs that credit toward

the OOPM or deductible only a participant’s costs after any coupon or discount could draw

scrutiny. Clarification from the agencies would be helpful.

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© MERCER 2019 12

Key goals

Require hospitals to post standard charge information.

Require healthcare providers, health insurance issuers and self-insured group

health plans to provide expected out-of-pocket costs for items/services before

patients receive care.

Expand predeductible coverage in HSA-qualifying HDHPs for medical care that

helps maintain the health of individuals with chronic conditions.

Treat certain arrangements, potentially including direct primary care arrangements

and healthcare sharing ministries, as eligible medical expenses.

Increase access to de-identified claims data from taxpayer-funded healthcare

programs and group health plans for researchers, innovators, providers, and

entrepreneurs. Provide this access while conforming to applicable laws and ensuring

patient privacy and security.

Increase permitted health FSA carryover amount.

R E G U L A T O R Y D E V E L O P M E N T S

2 0 1 9 E X E C U T I V E O R D E R O N H E A L T H C A R E P R I C E

A N D Q U A L I T Y T R A N S P A R E N C Y

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Final Hospital Rule

• Must publish standard charges covering

all services, including:

– Gross charges.

– Discounted cash prices for self-pay.

– Payer-specific negotiated charges.

– De-identified minimum and maximum

negotiated charges.

Common billing codes and description

must be provided for all categories.

• Hospitals must also provide information

on 300 shoppable services to consumers.

Can comply by providing a pricing tool.

– CMS chooses 70 services.

– Hospital chooses 230 other services.

Proposed Group Health Plan and

Insurer Rule

• GHPs and insurers must provide on a public

website the negotiated rates for all in-

network providers and historic payments

to out-of-network providers.

• GHPs and insurers must provide a

transparency tool for consumers to obtain

out-of-pocket cost information for all

covered services before they receive care.

• If insurers share savings with patients up-

front, rule would provide relief from MLR.

R E G U L A T O R Y D E V E L O P M E N T S

N E W T R A N S P A R E N C Y R U L E S

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R E G U L A T O R Y D E V E L O P M E N T S

T R A N S P A R E N C Y R U L E ─ O P E N I S S U E S

S h o p p a b l e

S e r v i c e sT i m i n gC o s tQ u a l i t y Difficulty

Litigation challenging the final hospital transparency rule has begun.

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© MERCER 2019 15

© MERCER 2019 15

WEALTH

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L E G I S L A T I V E D E V E L O P M E N T S

S E N A T E S T R U G G L I N G T O P A S S S E C U R E A C T

• Setting every community up for retirement enhancement (SECURE Act).

– (HR 1994) passed House by a vote of 417-3 on May 23.

– Bill eludes unanimous consent but could hitch ride on Dec. 20 spending bill.

• Effort to address multiemployer plan crisis is also demanding lawmakers’

time.

– House-passed bill (HR 397) would provide loans, grants to troubled plans.

– Senate Finance Committee leaders release reform plan outline on Nov. 20.

• Plan sponsors asking Congress to consider more pension funding relief.

– Ideas include extending interest rate “stabilization” and allowing more time to

amortize funding shortfalls.

– Also strong company interest in proposals to reduce PBGC premiums.

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L E G I S L A T I V E D E V E L O P M E N T S

A D D I T I O N A L L E G I S L A T I O N P E N D I N G

• Retirement Security and Savings Act (S 1431).

– Sweeping “Portman-Cardin” bill contains broad array of DC and DB reforms.

• Pension and Budget Integrity Act (HR 4035).

– Would take PBGC premiums “off budget”; remove incentive for more increases.

• Retirement Security Preservation Act (S 2352).

– Like provision in SECURE Act, would ease nondiscrimination testing for closed

DB pension plans.

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L E G I S L A T I V E D E V E L O P M E N T S

N O T A B L E P R O V I S I O N S I N S E C U R E A C T

• Ease nondiscrimination testing for closed DB plans and DC plans providing

"make whole" contributions if certain requirements are met.

• Encourage lifetime income payouts in DC plans.

– Require disclosure of annuity value of DC plan accounts on statements.

• Permit “open” DC multiple-employer plans.

• Increase cap on default contributions to auto-enrollment/escalation safe

harbors.

• Allow long-term part-time workers to participate in 401(k) plans.

• Let people tap retirement savings without penalty for expenses related to

childbirth or adoption.

• Make changes to required minimum distributions (RMDs).

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L E G I S L A T I V E D E V E L O P M E N T S

N O T A B L E P R O V I S I O N S I N P O R T M A N - C A R D I N B I L L

• Permit employer “matching” contributions tied to student loan repayment.

• Allow employers to self-correct most inadvertent plan violations.

• Allow larger catch-up contributions ($10,000) at age 60 or older.

• Encourage greater use of deferred annuities (QLACs) in DC plans.

• Expand 401(k) plan eligibility to part-time workers who complete between

500 and 1,000 hours of service for two consecutive years.

• Eliminate indexation of PBGC variable-rate premiums.

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R E G U L A T O R Y G U I D A N C E

S I G N I F I C A N T D E V E L O P M E N T S

• Internal Revenue Service

– Extension of nondiscrimination testing relief for closed DB plans.

– New benefits, rights and features testing relief for closed DB plans.

– New 403(b) plan documentary compliance program.

– 2019 Required Amendments List.

– Final rules on hardship distributions.

• Department of Labor

– Proposed rules on e-delivery of retirement plan notices.

– Final rules on association retirement plans and PEO plans.

– Final PTE for Retirement Clearinghouse auto-portability program.

• Pension Benefit Guaranty Corporation

– Proposed rules on ending publication of old lump sum interest rates.

– Substantive changes to instructions for various filings.

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R E G U L A T O R Y D E V E L O P M E N T S

T E S T I N G R E L I E F F O R C L O S E D D B P L A N S

• Closed DB plans have coverage testing problems.

– Population becomes disproportionately highly compensated.

– Can’t pass without being tested together with DC plan.

• IRS has issued limited relief.

– 2014 relief relaxes requirements for testing DB and DC plans together.

– 2016 proposed regulations provide broader relief, but with stringent conditions.

– Not helpful to some employers.

• New BRF testing relief issued last month.

– For plans that closed by Dec. 13, 2013.

– Available to employers that qualify for 2014 relief.

• IRS working to finalize regulations providing broader relief.

– Allow testing with matching contributions?

• SECURE Act includes nondiscrimination testing relief.

– Allows testing with matching contributions; includes BRF relief.

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R E G U L A T O R Y D E V E L O P M E N T S

P R O P O S E D D O L R U L E S O N E - D E L I V E R Y

• New safe harbor method for e-delivery.

– Keep disclosures on a website; notify participants how to access.

– Notice sent to participant’s electronic address.

– Participants could opt out for some or all disclosures.

– Existing safe harbor method still available.

– Would apply to all ERISA disclosures.

• Not available for welfare plans.

– Two sets of rules?

• Requests for comments and information.

– Comments on any aspect of the proposal.

– Information on additional ways to make disclosures more effective.

– Closed on November 22.

– Comments welcome on extending rules to welfare plans.

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R E G U L A T O R Y D E V E L O P M E N T S

P B G C P R O P O S A L T O E N D L U M P S U M R A T E S

• PBGC interest rates for lump sums.

– Used to calculate de minimis lump sums from terminated DB plans.

– Code section 417(e) once used PBGC’s rates for minimum lump sums.

• Some plans still use PBGC rates.

– Grandfathered lump sum rate (if produces larger lump sum than 417(e) rate).

– Actuarial equivalence.

– Cash balance plan interest crediting rate.

• PBGC intends to switch to 417(e) rates.

– Final set of rates for plans using PBGC rates.

– Final immediate rate = 1.5%; final deferred rate = 4%.

– How many plans affected?

• Employer considerations.

– Locked-in rates would create permanent minimum lump sum.

– Employees may not know about rate changes ─ communications issues?

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© MERCER 2019 24© MERCER 2019 24

EXECUTIVE

COMPENSATION

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• Builds on August SEC guidance confirming the sale of proxy voting advice is a

“solicitation,” making proxy advisers liable for false and misleading statements.

– Proxy adviser Institutional Shareholder Services (ISS) has filed a lawsuit

challenging this guidance.

• Would require proxy advisers to:

– Disclose material conflicts of interest.

– Give companies an opportunity to preview and respond to proxy adviser

reports before the firm sends advice to its clients, if the company files its

definitive proxy statement sufficiently in advance of the shareholder meeting.

P R O P O S E D S E C R U L E S

P R O X Y A D V I S E R R E G U L A T I O N

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P R O P O S E D S E C R U L E S

P R O X Y A D V I S E R R E G U L A T I O N

• Would require proxy advisers to:

Give companies a final notice of proxy voting advice at least two

business days before delivery to clients.

Include in voting recommendation report a hyperlink to a company’s

response to the proxy voting advice, if requested.

Comply within a one-year transition period.

Comments due Feb. 3.

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• Builds on announcement that SEC staff will no longer respond to all shareholder

proposal no-action requests.

• Would introduce tiered share ownership requirements for shareholders to

submit proposals:

P R O P O S E D S E C R U L E S

S H A R E H O L D E R P R O P O S A L P R O C E S S

Minimum continuous

ownership period

Minimum continuous ownership level*

Current Proposed

1 yearAt least $2,000 or 1% of

company share

$25,000

2 years $15,000

3 years $2,000

*Each shareholder would have to satisfy these requirements (no aggregation).

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• Would make it harder for shareholders to resubmit a proposal if it deals with

substantially the same subject matter as a prior proposal that failed to receive

minimum levels of support:

• Would add a “momentum requirement” that allows companies to exclude

proposals that failed to gain majority support 3x or more in the last five years and

experienced a 10% decline in support.

P R O P O S E D S E C R U L E S

S H A R E H O L D E R P R O P O S A L P R O C E S S

Number of times

voted on

(in last 5 years)

Minimum support required for most recent vote

(within last 3 years) to resubmit proposal

Current Proposed

1x 3% 5%

2x 6% 15%

3x or more 10% 25%

Comments due Feb. 3.

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Investors are pushing for more disclosure and oversight of Human Capital Management

Proposed SEC Disclosures

Would require companies

to disclose human capital

management policies,

practices.

Principles-based, not

prescriptive.

Would include measures

material to understanding a

company’s business, such as

how well it attracts, develops,

and retains personnel.

Shareholder Proposals

Gender pay equitySeek disclosure of pay gap between median male and

female employees.

Executive-employee pay disparity Ask companies to report/consider how executive pay compares with pay of lowest paid/all employees.

ESG metrics in incentive plans Ask companies to assess feasibility of including environmental, social and governance (ESG) metrics in

incentive plans.

P R O P O S E D S E C R U L E S

H U M A N C A P I TA L M A N A G E M E N T D I S C L O S U R E

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© MERCER 2019 30© MERCER 2019 30

MERCER RESOURCES

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M E R C E R R E S O U R C E S

• Health

– Huge Financial Stakes for Employers as Congress Looks for Deal on Surprise Medical Bills (12/12)

– More than 1K Employers Urge Senate to Repeal the “Cadillac Tax” (12/12)

– ACA Individual Statement Deadline and Good-Faith Relief Extended Again (12/4)

– New Transparency Regulations: Will Consumers Finally Be Able to Shop for Healthcare? (11/21)

– Congress Readying Renewal of PCORI Fee with Employer-Friendly Changes (11/14)

– 2020 Health FSA, Other Health and Fringe Benefit Limits Now Set (11/13)

– Warren Financing Plan Roils Medicare for All Debate (11/7)

– Mercer’s 2020 Quick Benefit Facts (11/6)

– IRS Outlines How Individual-Coverage HRAs Can Meet ACA Employer Mandate (10/29)

– The Flawed Logic of the Cadillac Tax, Explained (10/24)

– Impeachment Face-Off May Affect Health Legislation (10/3)

– Agencies Ease ACA Rule on Drug Coupons and Out-of-Pocket Costs (9/3)

– Senate Urged To Follow House in Voting To Scrap ACA’s Cadillac Tax (8/2)

– Democrats’ Divide Over Employer Health Coverage Flares at Debates (8/1)

– Employers Called to Action as Battle Intensifies Over Curbing Surprise Medical Bills (7/11)

– Executive Order Targets Price and Quality Transparency, and HSA/FSA Changes (7/10)

– Senate Panel OKs Surprise Medical Bill Reforms But Plans Changes (6/27)

– Top 10 Compliance Issues for 2020 Health and Fringe Benefit Planning (6/26)

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M E R C E R R E S O U R C E S

• Health (cont’d.)

– Final Rules Ease Restrictions on Health Reimbursement Arrangements (6/14)

– Senate Package Targets Healthcare Costs, Surprise Medical Bills (6/12)

– 2020 ACA Cost-Sharing Caps Set, Play-or-Pay Penalties Projected (5/8)

– “Medicare-for-All” Gets Hearing on Capitol Hill (5/2)

– Trump Administration Adjusts Course on ACA Case (3/27)

– 2019 Compliance and Policy Outlook for Employer-Sponsored Health Benefits (2/6)

• Wealth

– IRS Renews Closed DB Plan Testing Relief for 2020 Plan Year (8/23)

– IRS Gives Closed DB Plans Relief for Benefits, Rights and Features Testing (11/14)

– IRS Creates Program for 403(b) Plan Document Compliance (10/18)

– IRS Finalizes Hardship Distribution Rules (9/25)

– DOL Proposes New Electronic Delivery Rules for Retirement Plan Notices (11/1)

– DOL Auto-Portability Program is First To Gain DOL Approval (8/12)

– PBGC Proposal Would End Publication of Old Lump Sum Rates (9/30)

– PBGC Kills Premium-Reduction for Mergers, Requires More E-Filings (11/6)

– PBGC Simplifies 4010 Controlled-Group Filing Requirements (10/17)

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M E R C E R R E S O U R C E S

• Executive Compensation

– Are You Ready for the 2020 Proxy Season?

– ESG Metrics in Incentive Plans: Europe and North America Compared (12/4)

– Why Do Say-on-Pay Results Remain Consistent Year After Year? (9/9)

– Will New SEC Guidance Make Proxy Advisers More Accountable? (9/3)

– Business Roundtable Promotes Evolving Corporate Purpose: Will Companies Broaden Performance

Metrics?

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CLOSING COMMENTS

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L A W & P O L I C Y G R O U P

w w w . M e r c e r . c o m / L a w a n d P o l i c y

P r o v i d i n g t i m e l y a n a l y s i s o f r e l e v a n t l e g i s l a t i v e ,

r e g u l a t o r y , j u d i c i a l a n d p o l i c y d e v e l o p m e n t s .

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O N E M E R C E R A P P

Our One Mercer App, available on the App Store and Google Play, features reports,

videos and infographics on a variety of health, wealth, and career topics.

For policy and compliance and articles (GRISTs), go to Topics Law and Policy.

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FEBRUARY 11 2015

H E A L T H W E A L T H C A R E E R

Presenter

Title

London

Get Timely Insights and

Commentary on US Health

News

Every week on US Health News,

Mercer publishes our observations,

research and best thinking on the

most pressing healthcare issues

and the transforming healthcare

environment.

Sign up for our weekly subscriber

e-mail:

www.ushealthnews.mercer.com

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Quest ions?

Please type your questions in the Q&A section of the toolbar.

We’ll answer as many questions as possible.

To submit a question, go to the floating panel at the bottom of your screen,

click the circle with the three dots and select Q&A. Make sure to send

questions to "all panelists."

Feedback

Please fill out the feedback form at the

end of this webcast so we can continue to

improve. The form will pop up in a new

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L E G A L D I S C L A I M E R

Mercer is not engaged in the practice of law, accounting, auditing or medicine. Any commentary

in this report does not constitute and is not a substitute for legal, tax, auditing or medical advice

or services. Mercer recommends that employers secure the advice of competent legal, tax,

auditor or medical counsel regarding any legal, tax, audit or medical matters related to this

report or otherwise.

The information in this document and any attachments is not intended to be used, and cannot be

used, to avoid penalties assessed under the Internal Revenue Code or imposed by any

legislative body on a taxpayer or plan sponsor.

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W H O W E A R E

Mercer is a global force of 25,000 unique individuals with

a passion for enhancing the health, wealth and careers

of more than 100 million people worldwide. We’re united by a single

idea ─ to make lives better tomorrow through actions we can take today.