October 2023 HR Newsletter

03.10.23 02:44 PM By Forsite Benefits
ICHRA Explained: Advantages & Potential Pitfalls

Have you heard of the term ICHRA? (Individual Coverage Health Reimbursement Arrangement)

What is a ICHRA?
ICHRA is a form of providing insurance to employees without aligning with a health insurance carrier. Instead of choosing a carrier for a group offering, an employer gives a financial allotment to employees to purchase their own individual health insurance plan. 

Since the inception of the ICHRA legislation in 2020, Forsite Benefit has been evaluating their viability. In some instances, particularly organizations with lower wage earners, an ICHRA may be an option to consider.

Advantages to offering an ICHRA plan
  • Fixing health insurance budget to a set dollar amount per employee (similar to defined contribution)
  • Employee choice in carrier and plan
  • Getting out of the carrier selection process annually
  • Low wage earners working for small employers could benefit from subsidies

While this may be intriguing, employers need to also fully understand the pitfalls of offering an ICHRA in lieu of a group sponsored plan. 

Potential Pitfalls of offering an ICHRA
  • Potential financial penalties up to $4,460 per employee if not properly structured
  • Plan selection can be confusing to employees if not properly educated. 
    • (Ask your Forsite rep about our proprietary BenIQ healthcare literacy training)
  • Higher income households may be adversely affected
  • Individual plan benefits and networks are generally not as comprehensive as group plans

You can rest assured that Forsite fully reviews all market options which include ICHRA’s, QSEHRA, HRA, Level Funding and many more other strategies. With many plans renewing January 1st, your Forsite representative will be prepared to discuss with you all of your options to ensure you are providing the best possible plan to employees in the most efficient manner possible. 

If you wish to learn more about this topic sooner, please contact a member of your Forsite Team or view or flyer below for more information. 
Navigating Open Enrollment - Tips to Share with your Employees

As the seasons change and leaves begin to fall, another important event comes into view on the horizon: open enrollment. For employees of many companies, open enrollment marks a significant period where they can make crucial decisions about their employee benefits for the upcoming year.  

How can you best support your employees as they navigate open enrollment? Share these tips from our sister company, Motion Connected, to set them on the right path today. 

REMINDER - Oct. 15 Deadline for Medicare Part D Coverage Notices
Employers must notify Medicare-eligible policyholders if their prescription drug coverage is credible or not.

The Medicare Modernization Act (MMA) requires entities (whose policies include prescription drug coverage) to notify Medicare-eligible policyholders whether their prescription drug coverage is creditable, (which means that the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage) or non-creditable. 

Who Must Comply
The disclosure requirements in this section apply generally to employers sponsoring group health plans that offer prescription drug coverage to Medicare-eligible individuals.

Information Required 

Notifies Medicare-eligible individuals whether the plan's prescription drug coverage is creditable coverage, meaning the coverage is expected to pay, on average, as much as the standard Medicare prescription drug coverage.

Note: Individuals who do not maintain creditable coverage for 63 days or longer following their initial enrollment period for Medicare Part D may be required to pay a late enrollment penalty. Accordingly, this information is essential to the decision to enroll in a Medicare Part D prescription drug plan.

Who it must be provided to
  • Medicare-eligible active employees and their dependents 
  • Medicare-eligible COBRA individuals and their dependents 
  • Medicare-eligible disabled individuals covered under the prescription drug plan 
  • Any retirees and their dependents

Who it must be provided by
Employers who sponsor group health plans that offer prescription drug coverage to Medicare-eligible individuals

 When it is Due
  • Prior to the annual enrollment period for Medicare Part D that begins on Oct. 15th 
  • Prior to an individual's initial enrollment period for Medicare Part D 
  • Prior to the effective date of enrolling in the employer's prescription drug plan and upon any change that affects whether the coverage is credible 
  • Upon request by the individual 

Online disclosure to the Centers for Medicare & Medicaid Services is also required annually, no later than 60 days from the beginning of a plan year, within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status. 


Model notices/templates

These model notices may be used to satisfy this requirement, issued by the
Centers for Medicare & Medicaid Services. 

        • Medicare Part D – Creditable Coverage Disclosure Notice Template - [View]
      • Non-Creditable Coverage Disclosure Notice Template - [View]
New Form I-9 Includes Remote Verification Procedure for E-Verify Users​​

Recently, the U.S. Citizenship and Immigration Services (USCIS) published a new version of its Employment Eligibility Verification form, also known as Form I-9. 

Employers are required to use the new form exclusively beginning on Nov. 1, 2023. The Form I-9 instructions also clarify procedures for employers who are eligible to utilize remote examination as an alternative to the physical examination of employees’ documentation. Employers enrolled and participating in E-Verify may choose to examine documents remotely.

Dates of Use

Here is the timeline of important dates related to this update:

  • July 21, 2023: UCSIS announced a new Form I-9.
  • Aug. 1, 2023: USCIS published the revised Form I-9 and employers were allowed to begin using the new version.
  • Aug. 30, 2023: The deadline for employers to complete physical inspection of I-9 documents, if applicable.
  • Oct. 31, 2023: The expiration date of current Form I-9 (edition date Oct. 21, 2019).
  • Nov. 1, 2023: Employers must complete the transition to using the revised form to comply with federal employment eligibility verification requirements.

Remote Document Verification

Under current requirements, employers must physically inspect I-9 acceptable documents to certify their employees are authorized to work in the United States. However, the new form includes alternative remote verification procedures employers enrolled in E-Verify can use to comply with their Form I-9 obligations.

Employers can review published instructions from the USCIS for remote document verification for more information.

To Learn More

USCIS has published a complete list of Form I-9 updates. Contact us today for more Form I-9 resources. 

The content herein is provided for general information purposes only, and does not constitute legal, tax, or other advice or opinions on any matters. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy.

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