What is Telemedicine? A Cool Benefit or a Hot Mess?

We’ve had numerous inquiries lately about telemedicine benefits.  My clients most typically ask either “is this a group health plan?” or “is it just access to another provider?”  Clearly, there is much confusion surrounding telemedicine benefits.  Part of the problem is that the regulators have yet to issue guidance on how telemedicine should be treated.  All we can do is take what is a very innovative benefit and figure out how it fits into a complicated, and sometimes outdated, regulatory framework.

Let’s start by agreeing that telemedicine benefits are pretty cool.  With telemedicine, employees can usually see a doctor sooner than if they had to go to a doctor’s office.  Read More ›

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EAPs That Meet Four Requirements May Avoid Application of Health Care Reform

Benefits provided through an employee assistance program (“EAP”) may be considered group health plan coverage, which would subject the EAP to the health care reform requirements mandated by HIPAA and the Health Care Reform Act, unless the EAP meets the criteria for being “excepted benefits.”

In September 2013, the IRS, HHS, and DOL collectively issued Notice 2013-54, which stated that, through 2014, benefits provided through an EAP were considered excepted benefits if the EAP did not provide “significant benefits in the nature of medical care.”  The notice did not elaborate on the terms “significant” or “medical care,” but the notice permitted employers to use a reasonable, good faith interpretation of these terms.  Read More ›

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