As a result, it's full steam ahead on meeting near-term requirements, such as the need to issue a summary of benefits and coverage or "SBC" document in connection with open enrollment.
In addition, outlined below is a snapshot of how this decision affects Consumer-Directed Benefit Accounts, such as Health Care Flexible Spending Accounts ("FSAs"), Health Reimbursement Arrangements ("HRAs") and Health Savings Accounts ("HSAs"):
- Health FSAs are still subject to a cap of $2500 on salary reductions beginning with plan years starting on or after January 2013.
- Health FSAs, HRAs, and HSAs must still require a prescription to reimburse medical over-the-counter medicines;
- W-2 reporting is still required;
- Preventive care mandates (including contraceptive benefits) continue to apply to non-exempt health FSAs and HRAs; and
- Non-qualified HSA distribution excise tax continues at 20%.
The Court's complete set of opinions can be found here.
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