Rx Management – CoPay Accumulator Programs

With Accumulator Programs the manufacturer’s payments no longer count toward a patient’s deductible or out-of-pocket maximum. Employers and health plans could potentially save big money because accumulators shift a majority of drug costs to patients and manufacturers.

Normally, a manufacturer’s payments from a copay program count toward a patient’s deductible and annual out-of-pocket maximum. Once these annual limits are reached, the plan pays for all subsequent prescriptions.

Problem is the Accumulator Programs will lower a plan’s drug spending by discouraging the appropriate utilization of specialty therapies and reducing adherence.

You may recognize Copay Accumulator by other names; UnitedHealthcare uses the term “Coupon Adjustment: Benefit Plan Protection program,” Express Scripts uses the term “Out of Pocket Protection program.” Choose your poison, both are misleading, especially to the patient.

For a deep dive into the potential impact of CoPay Accumulator Programs I recommend reading the article (link below) from Adam J. Fein, Ph.D. (Drug Channels) that highlights many potential concerns to Copay Accumulator Programs. Copay Accumulators: Costly Consequences of a New Cost-Shifting Pharmacy Benefit


The IRS has announced the limits for HSAs have been revised for 2018. The adjustments are the result of changes made in the Tax Reform bill.

What changed? 

The annual HSA limit for family contribution went down from $6,900 to $6,850 and it is retroactively effective back to January 1st, 2018. The annual single limit of $3,450 remains unchanged.


Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Pill Pack – Helping Employees Manage Medications

Taking multiple medications? Having trouble remembering what and when you took those medications? Looking for a simple solution? Statistics show 40M American adults take more than 5 prescriptions every day, but 50% don’t take their meds as prescribed.

PillPack is a service that can help. No need to sort medications, wait in line at the pharmacy or chase down refills. Every month PillPack will deliver your medications, including vitamins and OTC’s, sorted by dose. PillPack will automatically work with your doctors and process refills, regularly reviewing your medication schedule and manage your bills and claims – directly with your insurance!

You’ll always know what you owe. There are no hidden fees. Each month you’re responsible for your monthly co-pay, vitamins and over-the-counter medications.

Whether for yourself, caring for a parent, child, or friend, PillPack makes medication easy.

“Cadillac Tax” and Health Insurance Industry Fee Delayed in Spending Bill

A major victory in the continuing resolution that is keeping the federal government funded. The package included an additional two-year delay of the Cadillac Tax on employer-sponsored health insurance plans until 2022 and a moratorium in 2019 of the Health Insurance Tax on all plans.

Previously suspended for 2016 and 2017, the 2.3% excise tax on U.S. medical device revenues also restarted on Jan. 1, but will now remain suspended for two years through the end of 2019.


Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

IRS will NOT accept 1040 without ACA Health Coverage Reporting

Employee Benefit Advisors recommends companies inform employees of the following. – The original announcement came out in October 2017, however EBA thought it would be a good reminder to post at this time.

Reminder: The new tax law does not actually repeal the individual mandate. It eliminates the penalty (penalty is zero) starting in 2019, not 2017 or 2018. However, the penalty can be reinstated with an update to the tax law.   The requirement for companies with 50+ FTEs to offer health insurance remains.


The IRS has stated that it will not accept Forms 1040 for the 2017 tax year if the taxpayer does not report on the ACA’s health coverage reporting requirements. This is the first year that the IRS has put in place system changes to its Form 1040 review process that would reject tax returns during processing in instances where the taxpayer does not provide this information.

Background. The ACA’s individual mandate requires most individuals to obtain minimum essential health insurance coverage for themselves and any dependents or pay a penalty. Form 1040 instructs taxpayers to report whether they (and every dependent listed on their return) had health insurance coverage, were eligible for an exemption from the ACA’s coverage requirement, or will make an individual shared responsibility payment.

For prior tax seasons, the IRS had delayed processing of tax returns that did not answer the health care coverage questions, but it did not prevent the return from ultimately being processed.

Guidance. For 2017 tax returns, the IRS has stated it will not accept the electronic tax return until the taxpayer indicates whether they (and all of their dependents) met the ACA requirements or are paying the penalty. In addition, returns filed on paper that do not address the ACA reporting requirements may be suspended pending the receipt of additional information, and refunds may be delayed.

In response to the IRS’s revised review process for Forms 1040, to avoid refund and processing delays when filing 2017 tax returns, taxpayers should indicate whether they (and everyone listed as dependents on their tax return) had health insurance coverage, qualified for an exemption or made a shared responsibility payment.

The IRS guidance is available at:


Content is provided for information purposes by The Wagner Law Group and may not be relied upon as specific legal advice.

IRS Guidelines – Indexed for 2018

Social Security Tax is 6.2% on income up to $128,400 up from $ 127,200
Medicare Tax unlimited 1.45% to Unlimited

High Deductible Health Plans
Minimum Annual Deductible (Individual/Family) $1,350 / $2,700
Maximum Out-of-Pocket Limit (Individual/Family) $6,650 / $13,300

Health Savings Accounts
Individual / Family $3,450 / $6,900 IRS announced change to $6,850 March 5, 2018
Catch-up Contribution $1,000

Flexible Spending Accounts
Health Care Flexible Spending Account Maximums $2,650
Dependent Care Spending Account Maximum $5,000

Mileage & Transportation
Standard Mileage Rates
54.5 cents per mile for business miles driven
18 cents per mile for medical or moving purposes
14 cents per mile driven in service of charitable organizations

Parking (monthly) $260
Mass Transit Passes (monthly) $260

Compensation Limit $275,000
Highly Compensated Employee Salary Amount $120,000
Annual Compensation for Key Employee $175,000
Defined Benefit Plan Limit $220,000
Defined Contribution Plan Limit $55,000

Retirement Plans
401(k) $18,500
401(k) Catch-up $6,000
403(b) $18,500
457(b)(2) and 124(c)(1) $18,500
457(b) Catch-up $6,000
IRA Limit $5,500/$6,500 for age 50+
Simple IRA Limit $12,500/$3,000 Catch-Up


Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Obamacare Driving New Wave of Hospital Bankruptcies

Health-care bankruptcy filings have more than tripled this year according to Bloomberg, and an index of Chapter 11 filings has reached record highs (industry companies with more than $1 million of assets). It’s expected that for 2018 the trend will increase; hospitals and other medical companies are likely to restructure their debt or file for bankruptcy.

How is Obamacre contributing to the hospital failures?  Obamacare’s architects were so certain their legislation would completely eliminate uninsured citizens in the U.S., they decided to offset the costs of the “Affordable Care Act” by eliminating subsidy payments to hospitals that had previously been used to cover losses from treating uninsured patients. Regulatory changes, technological advances and the rise of urgent-care centers have created a “perfect storm” for health-care companies.

Content source, ZeroHedge by Tyler Durden.


Pharmacogenetics allows prescribers and pharmacists to understand how medications react differently in the body based on an individual’s metabolism. Best Practice PBMs are able to apply the results of a fast and easy-to-administer pharmacogenetics test to enhance member safety, improve treatment outcomes and prevent wasteful drug spending.

The science of pharmacogenetics utilizes precision medicine, which evaluates and considers a patient’s metabolism, environment and lifestyle, to develop effective, individualized treatment plans. Pharmacists work with members and their prescribers to coordinate changes in drug therapies, as indicated by testing. This ensures that members receive the most clinically appropriate and effective medications. By proactively identifying which drug therapies will not work, or are likely to cause severe adverse reactions, clients and their members can avoid unnecessary risks and expenses.

Pharmacogenetic testing can have a measurable positive impact for members who live with chronic health challenges such as diabetes or high cholesterol. Pharmacists can help them move quickly onto the most appropriate drug therapy and improve their health with fewer side effects and less risk, based on their unique metabolism.

There are no doctor’s visits required to administer the test. Members can collect and submit the sample from home using a simple cheek swab. The markers identified by pharmacogenetic testing do not change over a member’s lifetime, so repeat tests are not required.

Pharmacogenetics enables a personalized approach to care aimed at reducing costs, improving treatment efficacy and preventing adverse drug reactions.

Please contact me if you would like to learn more.


Employee Benefit Advisory provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

PBM – Looking for transparency?

Are you contracting with a large PBM because they offer great discount? You might want to rethink your strategy and look to smaller PBMs with complete transparency. Perhaps it’s time to consider a pharmacy benefits administrator that offers the following:

  • A straight forward pricing model with no hidden revenue generators such as spread pricing. Look for invoice of the exact amount that reflects retail contracts. No spread should be retained for brands or generics.
  • Minimum retail guarantees, not maximums or estimates. If better rates are negotiated during the contract term, the PBM should pass through those discounts.
  • Mail order prescription charges based on the actual acquisition cost.  The amount billed should match the invoice cost, plus a fixed dispensing fee. Is your BPM willing to provide mail order purchasing invoices to validate their actual acquisition cost?
  • “Generic” and “Brand” defined exactly as Medispan does– no change in definitions.
  • No financial interest in any pharmaceutical manufacturer. BPM should pass through 100% of rebates received associated with a client’s brand utilization.
  • Fulfilled promises.  Annual reconciliation occurs and the BPM will make up any loss where the guarantee is not met by paying clients back for each dollar over the amount that was guaranteed.

Who is Employee Benefit Advisors describing? Contact us and make a referral on your behalf.


Employee Benefit Advisory provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

Knock Out Blow? – Trump Ends Cost-Sharing Reduction Subsidies

The White House confirmed Thursday that it will stop making federal payments for cost-sharing reductions, payments to health insurers. The Department of Health and Human Services confirmed that the cutoff would be immediate. This action could throw the Marketplace into immediate turmoil as insurers start to evaluate their options for 2018.

Many, certainly democrats, have been calling for a bi-partisan solution to the health care problems in America. However, let’s not forget, it was the democrats that ramrodded the misnamed Affordable Health Care Act through the legislative process, behind closed doors, with absolutely no input from republicans.

Employee Benefit Advisors has blogged several times about legal challenges to the ACA, specifically pin pointing, the Obama administration saying they did not receive, but needed, an appropriation to make these payments to insurance companies. Obama used executive orders to put into place key finance regulations behind the ACA. Problem is, what can be done by executive order can be undone by executive order.


Employee Benefit Advisors provides employee benefits, tax-advantaged healthcare, compliance guidance for ACA and Health & Welfare DOL Audits, and PEO Advisory & Consulting Services.

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