We previously wrote about President Biden’s announcement to end the COVID-19 Public Health Emergency (PHE) and National Emergency (NE) periods on May 11, 2023, and the practical ramifications for employer group health plan...more
As employers and insurers continue to establish programs to enable participants in group health plans to receive at-home COVID-19 tests at no cost, even without a prescription, the Department of Labor (DOL) has issued...more
In fulfillment of President Biden’s promise to make at-home COVID tests more available for all of us, two significant action steps have now occurred:
1.Every U.S. household has access to free at-home COVID-19 tests. As of...more
The IRS just released IRS Notice 2022-04 that provides the updated fee for Patient-Centered Outcomes Research Institute (PCORI) paid by fully insured and self-funded health plans for the upcoming tax reporting period...more
As employers consider implementing a vaccine mandate to encourage employees to get vaccinated against COVID-19, we have recently discussed the merits of imposing a “vaccine surcharge” on monthly health insurance premiums for...more
In our most recent summary of IRS Notice 2021-31, we noted the Internal Revenue Service provided much-needed clarity to looming compliance challenges as employers, insurers, and others race to implement the applicable COBRA...more
As the IRS continues to churn out guidance on various forms of COVID-19 relief, this week is no exception with the release of Notice 2021-26. This Notice clarifies two key points relating to the tax treatment of dependent...more
The Consolidated Appropriations Act, 2021 (CAA) amended the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) to include substantial new compliance requirements. The Department of Labor (DOL), Health and Human...more
The American Rescue Plan Act of 2021 (ARPA) is the latest federal COVID-19 relief bill, which the President signed into law March 11, 2021. ARPA includes new COBRA continuation coverage election, notice, and subsidy...more
3/12/2021
/ Affordable Care Act ,
American Rescue Plan Act of 2021 ,
Biden Administration ,
COBRA ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Defined Benefit Plans ,
Dependent Care ,
Employee Benefits ,
Employer Group Health Plans ,
Flexible Savings Accounts (FSAs) ,
Full-Time Employees ,
Pensions ,
Popular ,
Relief Measures ,
Tax Credits
We recently provided an update on the looming end date for COBRA and other deadline extensions and the uncertainty that continues to add to the administrative burdens without more clarity from the DOL and IRS. Message...more
3/1/2021
/ COBRA ,
Coronavirus/COVID-19 ,
Deadlines ,
Department of Labor (DOL) ,
Disaster Aid ,
Employee Retirement Income Security Act (ERISA) ,
Flexible Spending Accounts ,
Health Insurance Portability and Accountability Act (HIPAA) ,
IRS ,
New Guidance ,
Third-Party ,
Time Extensions
In May of 2020, the Department of Labor (DOL) and Internal Revenue Service (IRS) released joint-agency guidance that extended several important deadlines for employees, including COBRA election and payment deadlines, HIPAA...more
The Consolidated Appropriations Act, 2021 (Act) provides certain COVID-19-related relief, including temporary additional flexibility regarding flexible spending accounts (FSAs). Employers have several practical considerations...more
The Consolidated Appropriations Act, 2021, generally provides the annual funding for the federal government and, in almost 5,600 pages, contains several important rules giving further COVID-19 relief, including the expansion...more
IRS Notice 2020-44 was issued this week as a reminder that Patient-Centered Outcomes Research Institute (PCORI) fees were extended under the Further Consolidated Appropriations Act of 2020 and are now not scheduled to expire...more
The Department of Labor (DOL) and other federal regulators released updates and clarifications related to employee benefits, including updates to model COBRA notices and an extension of certain statutory deadlines intended to...more
As a result of the ongoing COVID-19 pandemic, we are observing all sorts of never-before-seen changes in the fully-insured group health plan space. Many insurers are liberally waiving their normal rules to accommodate the...more
With the combination of our nation’s response to COVID-19 and the resultant economic downturn, employers of all sizes face the moral and financial dilemma of evaluating employee headcounts while businesses are grappling with...more
3/23/2020
/ 401k ,
Affordable Care Act ,
COBRA ,
Coronavirus/COVID-19 ,
Employee Benefits ,
Employer Liability Issues ,
Furloughs ,
Hiring & Firing ,
Layoffs ,
Popular ,
Severance Pay
Like many other areas, employers are grappling with issues in response to the pandemic growth of the 2019 Novel Coronavirus (aka, “COVID-19”) in the workplace. One newer topic has been related to the desire to ensure...more
As we advised was likely during our June 29, 2019 webinar, Association Health Plans—Are They Really an Option to Consider?, at least two states were likely to challenge the enforceability of the new regulations issued by the...more
As discussed during our recent webinar, the finalized DOL regulations for qualifying “association health plans” will likely create new opportunities for sole proprietors and other primarily small businesses and other trade...more
On more than one occasion since passing the Affordable Care Act (“ACA”), the IRS has given some type of early holiday “gift” to alleviate pending compliance concerns for employers. One of the most significant of these...more