The Massachusetts Department of Family and Medical Leave (DFML) recently posted proposed changes to its Paid Family and Medical Leave (MAPFML) regulations. For the time being, these changes are presented as a “draft markup”,...more
Given the possible health impacts of COVID-19, maintaining access to health care and insurance coverage is front of the mind for just about everyone. Continuation coverage under COBRA offers employees a route to continue...more
In response to COVID-19, Massachusetts has directed health insurance carriers to, among other things, relax cost-sharing and enhance telemedicine services. These directives are part of the Commonwealth’s package of efforts...more
On March 12, 2020, the IRS issued notice 2020-15, providing that a health plan will not fail to be a High Deductible Health Plan (HDHP) merely because it provides testing for and treatment of COVID-19 without a deductible or...more
The 21st Century Cures Act (Cures Act), enacted on December 13, 2016, provides a new opportunity for small employers to help employees pay for health insurance: the “qualified small employer health reimbursement arrangement”...more
On October 21, 2016, the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (collectively, the Departments) issued a FAQ providing indefinite relief for employers who subsidize student health...more
On February 5, 2016, the Departments of the Treasury, Labor, and Health and Human Services (the Departments) issued guidance addressing the application of market reforms and other provisions of the Affordable Care Act (ACA)...more
While Americans everywhere were busy eating turkey and drinking eggnog last November and December, our government was hard at work attending to budget matters. Tucked among the appropriations were several fairly significant...more
In our prior installments, we determined that students who work at least 30 hours per week for their educational institutions are “full time” employees of those institutions under the Affordable care Act’s employer shared...more
In Part 2 of this miniseries, we discussed whether a student health insurance plan may be used to help an educational institution avoid penalties under t the Affordable Care Act’s “employer shared responsibility” mandate with...more
In the previous installment of this series, we addressed whether student employees may be excluded from an employer’s offer of coverage. We concluded that a blanket exclusion of this nature could put an employer at risk for...more
Educational institutions employ students in a variety of positions including work-study positions, teaching and research assistantships, and resident assistantships. This four-part series will discuss several issues that...more
On April 16, 2015, the EEOC published proposed regulations setting forth its position on the use of physical examinations under employment-based wellness programs. This comes as welcome guidance to employers who have...more
The United States has entered a new era of health care reform. Until now, United States employers were generally not required to provide health care coverage to employees (although many did so for employee relations and...more
On January 1, 2015, the Affordable Care Act’s (ACA) employer shared responsibility mandate took effect. Up until July 1, 2013, most employers doing business in Massachusetts were required to comply with an employer mandate...more
Since 2007, most Massachusetts residents have been required to either obtain health insurance coverage meeting Massachusetts “minimum creditable coverage” standards, or pay a state tax penalty (for 2014, the penalty ranges...more
As we reported in our post earlier today, the Obama administration has decided to delay implementation of the “employer shared responsibility” mandate for in order to afford employers more time to prepare for compliance. ...more