$100 $36,000 / DAY PER EMPLOYEE UP TO PENALTIES FOR NON- COMPLIANCE / YEAR 1954 §105 ADDED TO INTERNAL REVENUE CODE Section 105 allows an employer to offer a plan to reimburse employees’ qualified medical expenses, including insurance premiums. Amounts received excluded from employees’ income. 1961 REVENUE RULING 61-146 Allows an employer to informally pay for or reimburse an employee’s “premium for hospital and medical insurance,” tax-free, under IRC Section 106. Known today as an Employer Payment Plan. 1974 EMPLOYER RETIREMENT INCOME SECURITY ACT (ERISA) ERISA establishes fair and equal treatment requirements for employee benefit plans, supported by formal plan documents. 1996 EMPLOYEE MEDICAL PRIVACY LAW (HIPAA) HIPAA creates national standards to protect individual’s medical records and other personal health information, including insurance premiums. 2002 NOTICE 2002-45 (HRAs) The IRS Notice confirms an employer can offer a plan to reimburse employees’ qualified medical expenses, including insurance premiums. Known today as a Health Reimbursement Arrangement (HRA). 2006 ZANE BENEFITS INTRODUCES HRAs ZaneHRA offers employers a formal plan to reimburse employees’ qualified out-of-pocket medical expenses, including insurance premiums. 2010 AFFORDABLE CARE ACT (ACA) The ACA introduces sandardized health insurance to all Americans and requires group health plans to comply with new requirements effective January 1, 2014. 2013 NOTICE 2013-54 In coordination with the Dept. of Labor, the IRS confirms all group health plans, including HRAs and Employer Payment Plans, may not place limits on essential health benefits and must cover basic preventive healthcare services without cost sharing. Confirmed that Employer Payment Plans will not comply with the ACA Market Reforms. 2014 ZANE BENEFITS INTRODUCES HEALTHCARE REIMBURSEMENT PLANS (HRPs) Offers employers a formal plan (ZaneHealth) that continues to comply with IRS and ERISA requirements, in addition to new ACA Market Reforms (PHS Act 2711 and 2713). Effective for plan start dates beginning January 1, 2014. HOW ZANEHEALTH COMPLIES www.ZaneBenefits.com Can employers still reimburse employees for individual health insurance premiums? Yes! How? ZaneHealth offers employers a compliant health insurance reimbursement plan. AFFORDABLE CARE ACT To comply with ACA reforms, ZaneHealth: » Does not place an annual or lifetime limit on Essential Health Benefits (EHB). » Provides coverage for basic preventive care without cost-sharing. » Provides automated compliance with new administrative and reporting requirements. IRS To comply with IRS rules, ZaneHealth: » Automatically generates custom and accurate Plan Documents. » Ensures compliance with documentation and non-discrimination rules. HIPAA To comply with HIPAA Privacy Rules, ZaneHealth: » Reviews all reimbursement requests so the employer does not come in regular contact with Protected Health Information (PHI). ERISA To comply with ERISA, ZaneHealth: » Generates custom Summary Plan Descriptions (SPDs). » Follows ERISA rules in regards to individual health insurance reimbursement. Learn more at: COMPLIANCE TIMELINE HOW ZANEHEALTH WORKS The company uses ZaneHealth to give employees a monthly healthcare allowance. Employees purchase their own health plan and submit a reimbursement request. ZaneHealth reviews the request. The company reimburses employees via payroll, check, or direct deposit, up to their available balance. ZaneHealth is... » A group health plan. » A Section 105 Healthcare Reimbursement Plan (HRP). » A compliant plan, structured to comply with all applicable federal regulations, including the new ACA Market Reforms. ZaneHealth is not... » An Employer Payment Plan. » A Health Reimbursement Arrangement (HRA). Could employers pay penalties if the plan does not comply with federal regulations? Yes 2014 DEPT. OF LABOR FAQ In the FAQ, the Dept. of Labor reconfirms that premium reimbursement arrangements, such as HRPs, are group health plans. Emphasized compliance with the ACA Market Reforms. Understanding ZaneHealth Compliance