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COBRA Premium Assistance Expiration Notice

As the COBRA subsidy period comes to an end on September 30, 2021, plans are required to send a notice 15 to 45 days before an assistance eligible individual’s (“AEIs”) subsidy ends.  For AEIs whose subsidy period will end on September 30th, notices must be sent no later than September 15th.  The notice must describe: […]
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ICHRA Subject to ACA Reporting

An Individual Coverage Health Reimbursement Arrangement (“ICHRA”) became an available option for employers beginning January 1, 2020. An ICHRA is available to employers of any size to reimburse employees for individual health care coverage (i.e., health coverage bought through the Marketplace, private insurance, or Medicare Part A and B or C coverage), subject to certain […]
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“Long COVID” to Qualify as ADA Disability

Recent guidance released by the Department of Health and Human Services and the Justice Departments’ Civil Rights Division (“Joint Guidance”) confirms that people who continue to experience COVID symptoms months after first being infected may qualify as disabled under the Americans with Disabilities Act (ADA). Anyone who has had COVID-19, even where the initial illness […]
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Now Available – COBRA Subsidy Model Notices and Q&As

The American Rescue Plan Act of 2021 (“ARPA”) subsidizes the full COBRA premium for Assistance Eligible Individuals (“AEIs”) for six months between April 1, 2021 through September 30, 2021. To be eligible for this premium assistance,  the AEIs must: MUST have a COBRA qualifying event that is a reduction in hours or an involuntary termination […]
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Health Plan Administration Amid COVID-19 Disaster Relief Extensions – Employee Benefit Security Administration Disaster Relief Notice

The Department of Labor issued Notice 2021-01 on February 26, 2021 to address the expiration of the extension of certain benefit deadlines that expired on February 28, 2021. See the summary of Notice 2020-01 at the end of this blog for more information. Notice 2021-01 Notice 2021-01 confirms that the guiding principle for administering employee […]
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No Surprises Act

The No Surprises Act 2021 is set to take effect for health plan years beginning on or after January 1, 2022.  This legislation expands restrictions on charging health care plan holders out-of-network rates for certain services and includes many medical plan changes and requirements, some of which are listed below. No Surprise Medical Billing- amending […]
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Transparency Reporting Requirements under the CAA

The Consolidated Appropriations Act outlines new transparency requirements for covered service providers as it relates to ERISA group health plans.  The Act requires covered service providers, i.e., brokers and consultants to include certain disclosures regarding the receipt of direct and indirect compensation in contracts for services entered, extended, or renewed on or after December 27, […]

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The Consolidated Appropriations Act of 2021 Mental Health Parity Expansion – Reporting Requirements

Health plans and insurers that impose a nonquantitative treatment limitation (NQTL) on mental health or substance use disorder benefits (such as a restriction based on facility type) must perform and document a comparative analysis of the NQTL’s design and application. Other NQTL limit examples include quantitative (i.e., visit limits) and nonquantitative treatment limitations (i.e., preauthorization […]

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One Step Closer to the End of Surprise Medical Bills – Maybe

After ongoing negotiations for over two years, Congress has released Discussion Draft legislative text of the proposed No Surprises Act that seeks to protect patients from receiving surprise medical bills (unexpected medical bills for out-of-network and emergency care). Highlights of the Proposed Act Patients cannot be balance billed: by out-of-network providers at in-network facilities (with […]
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2020 Options for Unused Qualified Transportation Benefits Due to COVID-19

As a result of COVID-19, employees may be commuting less frequently to work, have changed their method of commuting (i.e. driving v. public transportation) or switched to telework. If your employees participate in a qualified transportation plan, they may have unused benefits. The IRS has released Information Letter 2020-2024 providing the following options for calendar […]
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