A COBRA subsidy is included in early drafts of the proposed fiscal year 2021 budget reconciliation package. If finalized, the COBRA subsidy would apply to workers who have lost group coverage during the COVID-19 pandemic due to involuntary termination or reduction in hours of employment. Briefly, The COBRA premium subsidy will be available to assistance […]
Summaries Medicare Part D – CMS Notification Reminder Employers sponsoring a group health plan are required by federal law to inform the Centers for Medicare and Medicaid Services within 60 days after the beginning of the plan year about the creditable status of the plan’s prescription drug coverage. Click below for a reminder of this […]
President Biden issued an executive order requiring the U.S. Department of Health and Human Services to consider having a mid-year special enrollment period for the federally-facilitated Marketplace to enable uninsured and under-insured consumers to obtain healthcare coverage.
Today the Departments of Labor and the Treasury issued guidance addressing the COVID-19 Outbreak Period. Unexpectedly, they have taken the interpretation that these benefit plan deadline extensions generally apply on an individual-by-individual basis.
The Department of Labor (DOL) published the annual adjustments for 2020 that increase certain penalties applicable to employee benefit plans. Annual Penalty Adjustments for 2021 The following updated penalties are applicable to health and welfare plans subject to ERISA. Description 2020 Penalty 2021 Penalty Failure to file Form 5500 Up to $2,233 per day Up […]
On January 7, 2021, the Equal Employment Opportunity Commission (“EEOC”) released two notices of proposed rulemaking (“Proposed Rules”) on wellness programs under the Americans with Disabilities Act (“ADA”) and the Genetic Information Nondiscrimination Act (“GINA”). Briefly, if finalized in their current form, the Proposed Rules: generally align ADA rules to existing rules applicable to “health […]
On the last day of 2020, the Wage and Hour Division of the Department of Labor (“DOL”) issued two additional FAQs (#104 and #105) related to the Families First Coronavirus Response Act (“FFCRA”), addressing the three-month voluntary extension of FFCRA leave into 2021, and clarifying payment of leave taken during 2020. The FFCRA required most […]
The Departments of Labor, Health and Human Services, and the Treasury (collectively, “the Departments”) announced a final rule that amends the requirements for grandfathered group health plans and grandfathered group health insurance coverage to preserve their grandfathered status. The final rules amend current rules to: provide greater flexibility for certain grandfathered group health plans to […]
On December 27, 2020, the Consolidated Appropriations Act, 2021 was signed into law and provides for relief related to the COVID-19 pandemic, as well as government funding. The legislation is tremendous and totals more than 5,000 pages. There are many different issues addressed, but this article focuses on the following components of the law that […]