Twelve for ’12: A Dozen Ideas for Flexible Benefits

The year 2011 will soon be in the history books so it is not too early to work on the master “to do” list for 2012. Here are a dozen suggestions for benefits and insurance professionals who are involved with flexible benefits, by Rich Glass, JD, Chief Compliance Officer, Infinisource, Inc.

• Keep an eye on the agencies. We expect major guidance to be issued in 2012. Look for final rules on nondiscrimination testing for fully insured plans (a new Patient Protection and Affordable Care Act (PPACA) requirement that was delayed by Notice 2011-1) and cafeteria plans, updating the proposed cafeteria plan regulations the IRS issued in 2007.
• It’s not as easy as S-B-C. Effective March 23, 2012, group health plans must provide a Summary of Benefits and Coverage (SBC). The PPACA limits the document to four pages in 12-point font. The rules don’t apply to health flexible spending accounts (FSAs), but they might apply to health reimbursement arrangements (HRAs).

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