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Compliance news ahead of 2019 renewals

We share the compliance updates employers and benefits consultants need to know.

Ahead of 2019 plan changes, employers and benefits consultants can take note of the following compliance updates. For client guidance or information on Healthgram self-funded plans, please contact our team.

ACA OOP Limitations


On April 17, 2018, the Department of Health and Human Services released the 2019 Affordable Care Act (“ACA”) out-of-pocket (“OOP”) maximums for 2019. ACA OOP limitations increased 7.48%.










HSA and HDHP Limitations


On May 10, 2018 the IRS released the health savings account (“HSA”) and high deductible health plan (“HDHP”) limits for 2019. For 2019, maximum HSA contributions increased 1.4% and HDHP OOP maximums increased 1.5%.




HSA Contribution Limit

Self-Only:        $3,450

Family:            $6,900

Self-Only:        $3,500

Family:            $7,000

Catch-Up Contribution Limit (for HSA-eligible participants who turn 55 by year-end)



Minimum HDHP Deductible

Self-Only:        $1,350

Family:            $2,700

Self-Only:        $1,350

Family:            $2,700

HDHP OOP Maximum

Self-Only:        $6,650

Family:            $13,300

Self-Only:        $6,750

Family:            $13,500

Poverty Guidelines


On May 21, 2018, the IRS released the 2019 Affordability Percentage (9.86%)  for employers using the federal poverty line safe harbor to avoid § 4980H(b) Employer Shared Responsibility penalties. As specified in FAQ No. 29, the following formula shows the maximum self-only monthly contribution for Plans using this safe harbor: (9.86% x 2018 Poverty Guideline) / 12.


2018 Poverty Guideline

Maximum Self-Only Monthly Contribution (2019)







Any other US State



District of Columbia




2019 Medicare Part D Benefit Parameters

On April 2, 2018, CMS issued the 2019 Medicare Part D Benefit Parameters used in determining whether coverage is creditable for required disclosures. View guidance here. Pages 67-68 show the “Standard Benefit” parameters for 2019, which will be used to determine whether coverage is creditable:


Standard Benefit

2019 Parameter

Change from 2018



+ $10.00

Initial Coverage Limit


 + $70.00

Out-of-Pocket Threshold (see FN1)


+ $100.00

Total Covered Part D Spending at the Out-of-Pocket Threshold for Non-Applicable Beneficiaries (defined in FN3)


+ $145.00

Estimated Total Covered Part D Spending for Applicable Beneficiaries (defined in FN4)


– $278.06

Minimum Cost-Sharing in Catastrophic Coverage Portion of the Benefit

Generic / Preferred Multi-Source Drugs


+ $.05



+ $.15


For more information about Creditable Coverage, please visit the Creditable Coverage section of


Preventive Service Guidelines


§ 2713 of the Affordable Care Act provides sources for preventive services that must be covered under the health reform law without cost sharing requirements, which are generally summarized at The specific resources for employers and plan advisors to review include:


  1. [E]vidence-based items or services that have in effect a rating of ‘A’ or ‘B’ in the current recommendations of the United States Preventive Services Task Force;”
    1. Find more specific guidance here.
    2. The following items were released in 2018:





Release Date of Current Recommendation

Cervical cancer screening The USPSTF recommends screening for cervical cancer every 3 years with cervical cytology alone in women aged 21 to 29 years. For women aged 30 to 65 years, the USPSTF recommends screening every 3 years with cervical cytology alone, every 5 years with high-risk human papillomavirus (hrHPV) testing alone, or every 5 years with hrHPV testing in combination with cytology (cotesting).


August 2018*

Falls prevention: older adults The USPSTF recommends exercise interventions to prevent falls in community-dwelling adults 65 years or older who are at increased risk for falls.


April 2018*

Osteoporosis screening: postmenopausal women younger than 65 years at increased risk of osteoporosis The USPSTF recommends screening for osteoporosis with bone measurement testing to prevent osteoporotic fractures in postmenopausal women younger than 65 years who are at increased risk of osteoporosis, as determined by a formal clinical risk assessment tool.


June 2018

Osteoporosis screening: women 65 years and older The USPSTF recommends screening for osteoporosis with bone measurement testing to prevent osteoporotic fractures in women 65 years and older.


June 2018*

Skin cancer behavioral counseling The USPSTF recommends counseling young adults, adolescents, children, and parents of young children about minimizing exposure to ultraviolet (UV) radiation for persons aged 6 months to 24 years with fair skin types to reduce their risk of skin cancer.


March 2018*

*Previous recommendation was an “A” or “B.”


  1. “[I]mmunizations that have in effect a recommendation from the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention with respect to the individual involved;”
  2. “[W]ith respect to infants, children, and adolescents, evidence-informed preventive care and screenings provided for in the comprehensive guidelines supported by the Health Resources and Services Administration.”
  3. “[W]ith respect to women, such additional preventive care and screenings not described in paragraph (1) as provided for in comprehensive guidelines supported by the Health Resources and Services Administration for purposes of this paragraph.”



Per IRS guidelines, the PCORI fee for plan years ending on or after Oct. 1, 2018, and before Oct. 1, 2019, is equal to $2.45 per covered life, an increase from $2.39.


2019 FSA Contributions

Beginning in 2019, employees may contribute an additional $50 to their flexible spending accounts, per IRS guidelines given in November. Adjustments to contribution limits are typically made in October, ahead of many Open Enrollment periods. If an employer decides to adopt the new limits, this delayed IRS announcement may require swift communication by human resources teams.



FSA Contribution Limit





To speak with a member of our team regarding Healthgram self-funded plans, contact us here.


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