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About Tina Bull

Tina Bull, VP of Compliance Services for the Employee Benefits practice, is responsible for managing and overseeing all activities of the Compliance Services Department. She advises and assists clients with respect to health/welfare plan design, administration and communication, with focus on current benefit laws and regulations. Tina’s areas of expertise include: Internal Revenue Code and ERISA requirements for health and welfare benefit plans; Internal Revenue Code Section 125 cafeteria plan implementation and administration; COBRA administrative requirements; HIPAA administrative simplification, privacy and security compliance and benefit taxation issues. In addition to conducting internal training for employee benefits staff, she has spoken at numerous seminars on regulatory compliance issues.

IRS Employer Mandate Penalty Assessments Begin

Tina Bull • Nov 30th, 2017

The Internal Revenue Service (IRS) has begun assessing Affordable Care Act (ACA) employer mandate penalties for 2015 by sending certain employers Letter 226J, the preliminary tax penalty notification letter. Continue Reading

Executive Branch Takes Action on the ACA (Benefit Minute)

Tina Bull • Oct 17th, 2017

Executive Order on ACA

In the last week, the Trump administration has taken action to make changes to certain aspects of the Affordable Care Act (ACA).  This action includes two new interim final regulations that scale back the ACA’s contraceptive coverage mandate, an Executive Order related to association health plans (AHP), health reimbursement arrangements (HRA) and short-term limited-duration insurance, and an announcement from the Centers for Medicare and Medicaid Services (CMS) that government payments to insurers for cost-sharing reductions will cease immediately.  The recent flurry of activity appears to be the administration’s response to the failure of repeal and replace legislation to move through Congress. Continue Reading

Recent Court Cases Impacting Employee Benefits (Benefit Minute)

Tina Bull • Sep 27th, 2017

This issue of the Benefit Minute summarizes recent judicial activity which may affect employers and their benefit plans. Continue Reading

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Drug Importation Program Risks (Benefit Minute)

Tina Bull • Aug 30th, 2017

The continuing increases in prescription drug costs has led some group health plan sponsors to consider arrangements whereby employees are provided with a referral to an international pharmacy or dispensing service to obtain drugs from outside the United States.  This referral program will generally be offered on a voluntary basis (in addition to other prescription drug benefits offered under the plan) and provide for purchase of brand name drugs at little or no cost to the employee or dependent. Promoters of these programs view them as an expansion of the FDA’s long-standing practice of allowing individuals to import prescription drugs for their own personal use.  Continue Reading


HIPAA and the Cloud (Benefit Minute)

Tina Bull • Jul 27th, 2017

Cloud computing allows convenient on-demand network access to a shared pool of computing resources (such as networks, servers, storage and applications) that can be rapidly supplied and used with minimal management effort or service provider interaction.   The computing resources are pooled to serve multiple customers and can be scaled to meet changes in demand.  Continue Reading


Compliance Updates (Benefit Minute)

Tina Bull • Jun 29th, 2017

This issue provides a summary of recent regulatory, judicial and legislative activity. Continue Reading

What is a Controlled Group?

Tina Bull • May 31st, 2017

When several entities (whether incorporated or unincorporated) share common ownership, a controlled group or common control may exist.  For many IRS benefit plan purposes, a controlled group is treated as a single employer.  For example, the determination of an employer’s size for purposes of COBRA, Medicare Secondary Payer rules and the ACA’s Applicable Large Employer status are determined on a controlled group basis.  IRS non-discrimination testing is generally performed on a controlled group basis.  This Benefit Minute provides a high level overview of controlled groups. Continue Reading

Final Rule Addresses ACA Marketplace Stability

Tina Bull • Apr 26th, 2017

The Centers for Medicare and Medicaid Services (CMS) has issued a final Market Stabilization Rule that is intended to help lower premiums and stabilize the individual and small group markets as well as increase health insurance choices in markets that are threatened by insurer exits. Continue Reading


The ACA Is Still the Law of the Land (Benefit Minute)

Tina Bull • Mar 29th, 2017

Republican efforts to repeal and replace parts of the Affordable Care Act (ACA) with the American Health Care Act (AHCA) stalled on March 24, 2017 when Speaker of the House Paul Ryan determined he did not have the support needed to pass the bill in the House of Representatives and withdrew it without a vote. Detractors of the bill included all Democratic members of the House, as well as the Freedom Caucus, a conservative group of Republican representatives who felt the bill did not go far enough to repeal the ACA. Moderate Republicans were also concerned by the Congressional Budget Office report which estimated that, by 2026, 24 million more people would be uninsured relative to the number of uninsureds under current law. It appears the administration and the Republican leadership will table current health care reform efforts for now and move on to other agenda items. Continue Reading