Ashley Gillihan moderated the panel "Prepaid Health Care and Benefit Cards: Expert Insights and Practical Tools for Ensuring Compliance" on June 24, 3:30pm - 5:30pm. His discussion covered the following topics.
Understanding the Product/Service: Benefit Offerings and Prepaid Cards
• Health (including FSAs, HRAs, and HSAs)
-Tax substantiation rules (including IIAS and IRS Notice 2006-69)
• Transit: IRS requirements applicable to transit and parking plans
• Wellness: Compliance issues associated with “wellness” incentives
• Dependent Care: Why IRS rules make dependent care administration difficult
• Multi-pursing
-Mixing restricted and unrestricted buckets
-Compliance issues associated with credit products under ERISA and the tax code
The Regulatory Environment and Best Practices
• HIPAA
• ERISA
• Tax and insurance law/regulatory considerations
• Banking Rules (GLB, AML, Reg E, etc.)
• Managing unique privacy/security risks of health benefit cards
-Impact of stimulus package on HIPAA requirements
-IRS doc retention requirements vs. HIPAA requirements
• Prohibited Transaction Limitations
-Notice and disclosure requirements for indirect compensation
• Developing and implementing a health care prepaid program
This conference was hosted by American Conference Institute. With the number and variety of prepaid products expanding at a rapid pace, it is more important than ever to ensure compliance with the myriad state and federal regulations and emerging legislation that impact the prepaid industry. As new features are added to existing products, regulations that were previously not applicable are now relevant. New AML initiatives require the reassessment of compliance processes and procedures to make certain that they adequately mitigate the risks of money laundering and fraud.
June 23-25, 2009
Park Hyatt Washington / Washington, DC