President Biden announced that the COVID-19 Public Health Emergency (PHE) and the National Emergency declared by President Trump in 2020 will end on May 11, 2023. The PHE relief issued in response to the pandemic affected group health plan coverage requirements related to COVID-19 prevention and treatment. The National Emergency relief suspended deadlines that
Happy National Employee Benefits Day – – April 5, 2022!!
Last year about this time, we wrote of how far we had come collectively in the world of employee benefits roughly one year after the onset of the COVID-19 Pandemic. We reveled at how we kept on keeping on, what we were able to accomplish in the face of unprecedented everything, and admirably pivot with
A Brief Status Report On COBRA
The normal difficulties that employers have adhering to the technical requirements of COBRA have been exacerbated during the past two years as COBRA rules were changed to recognize the complications accompanying the COVID-19 pandemic. This added complexity is particularly worrisome as an employer’s simple oversight in administering COBRA can result in ERISA penalties, an excise
More Clarity Regarding Employer Mandates for At-Home COVID-19 Testing
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 additional guidance and an updated FAQ providing further clarification and flexibility to insurers and plan sponsors in providing coverage to eligible
At-Home COVID-19 Testing Options and Alternatives
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:
- Every U.S. household has access to free at-home COVID-19 tests. As of January 18, 2022, any individual with a residence in the United States may request up to four (4) at-home
The Pandemic Continues, but ACA Reporting Relief Does Not
As employers with 50 or more full-time (or full-time equivalent) employees are well aware, the Patient Protection and Affordable Care Act (”ACA”) requires annual submission of Forms 1094-C and 1095-C with the Internal Revenue Service, and distribution of Forms 1095-C. These submissions and distributions are generally due:
| Furnishing of Forms 1095-C to employees: | January 31 |
Employer Vaccine Surcharges—Yes, You Can!
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 those employees who remain unvaccinated. There were unanswered questions about specific legal issues, but now the Department of Labor (DOL), Health and Human
2021 Plan Amendment Deadlines and Other Looming Fourth Quarter Considerations
As the year draws to a close, it is helpful for employers to pause to evaluate employee benefit plan amendment deadlines and other crucial fourth-quarter considerations, including: More…
Money Money Money: How Much can the Health Plan Surcharge on Unvaccinated Employees Be?
In light of the lingering COVID-19 pandemic and its impact on employee productivity and health care expenses, employers are considering imposing a premium surcharge on employees participating in the company’s health plan who are not vaccinated against COVID-19.
As we have discussed here, several federal laws must be taken into consideration when designing such
At Home COVID-19 Testing and the Path out of the Pandemic
Testing for COVID-19 certainly has evolved over the past 18 months or so. As supply and allocation continue to face challenges, guidance on serological/antibody versus viral testing, testing in the workplace, informed consent, among other things have emerged to help guide coronavirus testing in the workplace. President Biden’s Path out of the