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 sponsors as they administer COBRA, special enrollment, and other related deadlines tied to the end of the NE. As discussed, this action
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National Employee Benefits Day is April 6th!
With another National Employee Benefits Day upon us, it is a good reminder for all involved in the world of Employee Benefits to pause (take three deep breaths) and use it as an opportunity to look back at where we’ve been over the last year and where we are going. While the challenges are many…
What the End of the COVID-19 Pandemic Means for Employee Benefit Plan Deadlines and Coverage
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
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Pre-Thanksgiving ACA Reporting Relief That’s No Turkey
Just three weeks ago, we wrote that employers likely would not receive certain Affordable Care Act reporting relief to which they’ve become accustomed.
But in a welcome turn of events, the IRS just released proposed regulations that make permanent a 30-day automatic extension for furnishing Forms 1095-B and 1095-C to individuals. Such forms will now…
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 |
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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…