IRS Provides Guidance on Health FSA $2,500 Limits
In a recent Notice, the IRS provided guidance on the effective date of the $2,500 limit on salary reduction contributions to health flexible spending arrangements (“Health FSAs”) and on when plans should be amended to comply with the limit
Background. Under the Patient Protection and Affordable Care Act (“PPACA” or “Health Care Reform”), the annual contributions permitted for an employee under the Health FSA component of a Cafeteria Plan will be capped at $2,500. This is effective for “taxable years” beginning after Dec. 31, 2012.
New guidance. Notice 2012-40 provides the following guidance and clarifications regarding the $2,500 limit.
- The $2,500 limit does not apply for plan years that begin before 2013.
- The term “taxable year” refers to the plan year of the cafeteria plan (and not the tax year of the employee or employer). This means the period for which salary reduction elections are made.
- If a cafeteria plan has a short plan year beginning after 2012, the $2,500 limit must be prorated accordingly.
- The $2,500 Health FSA cap does not apply to any other “flex credit” offered under a Cafeteria Plan (such as dependent care assistance).
- Plans may adopt the required amendments to reflect the $2,500 limit at any time through the end of calendar year 2014, provided that they otherwise operate in accordance with the new limit requirements.
- In the case of a plan providing the optional grace period, unused salary reduction contributions to the health FSA for plan years beginning in 2012 or later that are carried over into the grace period for that plan year will not count against the $2,500 limit for the subsequent plan year.
- If one or more employees are erroneously allowed to elect a salary reduction exceeding the Health FSA limit, the Cafeteria Plan will not lose its qualified status if: (1) the terms of the Plan apply uniformly to all participants, (2) the error was a reasonable mistake and not due to willful neglect, and (3) the excess amount is paid to the employee and treated as taxable wages.
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What’s the Difference between Performance & Proficiency?
By Mykkah Herner, MA, CCP, Compensation Consultant at PayScale.com
Here at PayScale, we often talk about compensation philosophies answering 3 main questions:
- How do you define your market?
- How competitive do you want to be relative to the market?
- What do you want to reward?
In working with clients, I find they know the answers to the first two questions within a heartbeat. The third question, however, often leads them to stumble and to look to me for guidance. What are the options? What should we reward? At that point, I have to dig in deeper to their organization.
There’s no single right answer for what companies *should* reward. In some orgs, there will be just one thing to reward, in some it will be a combination of factors. At a time when most companies are focused on pay-for-performance, I want to explore this third question a bit further.
What do you want to reward?
Performance
Ultimately, for me, it will always come down to some variant of performance. If your employees aren’t going above and beyond, exceeding expectations most of the time, it’s likely that your organization will stagnate. Stagnation is close to death in a highly competitive environment. The number one question I ask myself when defining a compensation strategy is how am I going to motivate employees to perform? In measuring performance, it is about setting clear expectations, in the form of metrics, for what it looks like to excel and then following up on those expectations.
Proficiency
What’s the difference between performance and proficiency anyway? I see proficiency as one’s ability to perform the tasks required to do the job, having the right skill-set, etc. Performance refers to how well one performs those required tasks, exceeding expectations vs. meeting expectations, and so on. I know that’s simplistic, but breaking it down to that level helps me then think about how I might measure proficiency. Some measures for proficiency include checking that one has skills and ensuring that tasks have been completed.
Tenure
The average tenure in my parents’ generation was 5+ years. My generation can boast a meager 3 years. The average tenure in newer generations to the workforce can be measured in months, not years (usually 12-18, according to one researcher). With that in mind, rewarding tenure can sometimes be helpful to the continuity of your organization, but it still may not be the right motivator for performance. You may have better luck achieving continuity through structural means rather than through compensation.
Other options?
There are plenty of options besides the big three listed above. For some, it will make sense to reward certain skills. I’ve worked with clients who couldn’t get by without their technical staff. For them, targeting a higher percentile for their technical staff was crucial to accomplishing their business goals. For other clients, security clearances are a hot commodity. You know what’s important to your organization. Put your money where your priorities are.
Remember, you don’t have to reward all things equally. You may decide that you want to tie a large part of your compensation to performance, but still give token acknowledgments for proficiency and tenure. But be sure to keep it simple. Explain it easily and succinctly – and maybe you will avoid a few headaches for your payroll team.
Whatever you decide, live it as an organization. Make sure your managers and leaders buy in to your decision around what to reward. Explain your philosophy to your staff so they are clear about what’s important to your organization. And, as with all policy decisions, once you decide what you want to reward, stick to it.
More than 80% of employers look to adviser for PPACA education
Beginning in 2014, the Patient Protection and Affordable Care Act requires employers with more than 50 employees to offer minimal essential health coverage to employees or be subject to a penalty. More than three-fourths of employers plan to continue to offer coverage for employees once this new requirement takes effect. However, a majority of respondents are also concerned about their ability to offer affordable health coverage to full-time employees.
The 2012 Health Care Reform Survey was conducted from January 6 to February 24 by Milwaukee-based Zywave, a software provider for the insurance and financial service industries. More than 7,800 employers nationwide participated in the survey.
Respondents are from 14 business sectors, with heaviest representation from services (18%), manufacturing (15%), nonprofit (11%), health care (10%) and construction (9%). Respondents spanned organization size: 43% with less than 50 employees, 17% with 50–99 employees, 27% with 100–499 employees and 14% with more than 500 employees.
Among those surveyed, 51% will definitely continue to offer health benefit coverage, 29 % will likely continue coverage, 3% will likely discontinue coverage and 1% will definitely discontinue or have already discontinued coverage. Meanwhile 19% are unsure what they will do when the requirement goes into effect in 2014.
“These findings are consistent with other recent surveys on the topic,” says Zywave attorney Erica Storm. “Given the uncertainty surrounding health care reform, employers do not appear eager to make big changes to their benefit offerings. Plus, employers remain concerned about competing for talent and seem nervous that dropping coverage could affect recruiting and retention efforts, despite other health care options provided for in the law.”
Other survey results include:
• 57% of employers responding are concerned about their ability to offer affordable health coverage to full-time employees.
• More than three-quarters of respondents have already seen an increase in their organizations health benefit costs or expect to see an increase as a result of PPACA provisions. Sixty-three percent of employers plan to pass these increases on to employees.
• PPACA requires group health plans that provide dependent coverage of children to make that coverage available to children up to age 26. In response to this requirement, 10% of employers surveyed increased the employee share of premiums or benefit costs for all coverage, 9% increased the employee proportion of dependent coverage cost and 2% eliminated dependent coverage.
• PPACA provisions that employers are most concerned about implementing and administering include: new reporting, disclosure and notification requirements (57%), the requirement to automatically enroll new employees in a health plan (40%) and additional W-2 reporting requirements (49%).
By Marli D. Riggs
Employers Get Creative with Tight Budgets....
Voluntary benefits are on the rise, but why is that the trend we are seeing? The economy is in recovery, but it is and will continue to be a slow climb up a very tall mountain. Company belts have not loosened and with the overall impact of healthcare reform still uncertain, it still may be quite some time before they let those belts out a notch or two.
According to HR Daily Report, this is why more employers are looking at Voluntary Benefits as a lower-cost incentive to attract new and retain existing talent. Employers are taking to offering employees everything from auto and home insurance to legal plans or even pet insurance. All of these being growing trends in employers looking to stay competitive. That's the assertion at a recent presentation at the 2011 Health Care Benefits NY conference. Outlined in the course of that presentation was a list of the most popular group voluntary benefits, now and in the future.
Most popular now included:
- life insurance
- disability (long and short-term plans), and
- vision plans
- long-term care
- legal plans, and
- auto and home insurance
- Because it provides protection against lost income, disability insurance (short and long-term) is perhaps the most popular voluntary benefit today.
- The financial security afforded by life insurance makes it an especially popular voluntary benefit in uncertain economic times. While term life is still most prevalent, a "fight to qualify" among employers and employees is making permanent life insurance more popular.
- Voluntary dental insurance holds great appeal to both employees and employers because you can design plans so that it is not very expensive.
- Relatively new among voluntary benefits, supplemental limited-benefit plans that provide a set dollar amount per day for hospital stays are gaining popularity, as are gap insurance policies that pay a certain amount up to a deductible.
- More targeted in their coverage, but also appealing, especially to small businesses with high-deductible plans, are supplemental accident insurance and critical illness insurance.