On November 22, 2021, the Internal Revenue Service (“IRS”) released proposed regulations that provide some relief with respect to ACA reporting requirements. The proposed rule: Makes permanent an automatic extension of 30 days to furnish IRS Forms 1095-C (and 1095-B) to individuals. Effectively, this moves the due date for furnishing these forms to full-time employees […]
Legaspi Associates, Inc. has merged into Imperial Coverage, an innovative new insurance firm launched to help ensure clients are properly protected in all critical ways. The independent, full-service company offers comprehensive personal and business insurance solutions. Mark Legaspi, who led his own firm for over two decades and brings 30 years of industry experience to […]
The IRS recently released cost of living adjustments for 2022 under various provisions of the Internal Revenue Code (the Code). Some of these adjustments may affect your employee benefit plans. Cafeteria Plans – Health Flexible Spending Arrangements Annual Contribution Limitation For plan years beginning in 2022, the dollar limitation under Code Section 125(i) for voluntary […]
On November 5, 2021, the Occupational Safety and Health Administration (OSHA) published its long-awaited Emergency Temporary Standard (ETS), which requires most U.S. employers with 100 or more employees to adopt a mandatory COVID-19 vaccination policy with an option to include an alternative weekly testing program. The ETS is effective immediately and employers must begin their […]
On October 15, 2021, the Secretary of Health and Human Services (“HHS”) renewed the COVID-19 pandemic Public Health Emergency, effective October 18, 2021. This will once again extend the Public Health Emergency period for an additional 90 days and as a result, numerous temporary benefit plan changes will remain in effect. Important Definitions Emergency Period. […]
The Biden administration recently announced a new framework for the budget reconciliation package, known as the Build Back Better Act (H.R. 5376). The legislation is still being negotiated, and the timing for when a vote is expected is uncertain. If the proposed legislation is enacted into law in its current form, several provisions would have […]
Recently, the Internal Revenue Service (“IRS”), in coordination with the Departments of Labor and Health and Human Services (collectively, “the Departments”), issued Notice 2021-58 which clarifies the deadlines for making COBRA elections and premium payments under the Outbreak Period rules. Background Briefly, in response to the COVID-19 pandemic, the Departments issued Emergency Relief Notices that […]
The Department of Health and Human Services (“HHS”) issued guidance in the form of questions and answers addressing how the HIPAA Privacy Rule applies in regard to COVID-19 vaccinations. The guidance makes clear that HIPAA’s privacy rules are not an obstacle to an employer that would like to establish a vaccination requirement for its employees […]
The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) was signed into law on March 27, 2020. Among other things, the CARES Act offered temporary relief related to telehealth and other remote care services when offered with a qualified high deductible health plan (“HDHP”) and health savings account (“HSA”). Specifically, for plan years […]
On October 4, 2021, the Departments of Labor, Health and Human Services, and the Treasury (together, the “Departments”) issued FAQ Part 50 addressing several important issues concerning group health plans. Notably, the guidance: Confirms incentives in a group health plan (such as premium discounts) are permissible under the HIPAA health-contingent wellness program rules provided the […]