“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 […]
Read More
Contribution Health Logo

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 […]
Read More
Contribution Health Logo

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, […]

Read More
Contribution Health Logo

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 […]
Read More
Contribution Health Logo

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 […]
Read More

Affordable Care Act Reporting for 2020

Employers face a great deal of challenges in 2020 related to COVID-19, including lock down orders, supply chain disruptions, and virtually unprecedented economic uncertainty.  The patchwork of state and federal responses to assist business, ranging from forgivable loans to deadline relief, does not currently extend to relief from the annual information reporting requirement under the […]
Read More
Contribution Health Logo

IRS Notice 2020-29: Relief for Section 125 Cafeteria Plans and Flexible Spending Accounts

Background By now, employers are probably used to seeing regular updates and rule changes issued by various federal agencies including the Department of Labor and Internal Revenue Service that are in some way related to COVID-19.  Additional guidance issued on May 12, 2020 from the IRS provides relief to employees who are seeking to change […]
Read More

FFCRA and CARES Act

FFCRA & CARES Act – Overview of Benefits Changes President Trump signed into law two major pieces of legislation aimed to provide relief in various forms to business, individuals, and government agencies – the Families First Coronavirus Response Act (“FFCRA”) and the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”).  Both laws make major […]
Read More
Contribution Health Logo

U.S. House of Representatives Passes Coronavirus Relief Act

On March 14, 2020, the United States House of Representatives passed bipartisan legislation authorizing funding for supplemental food relief and testing related to the Covid-19/Coronavirus pandemic.  While this bill does not take effect until approved by the Senate and signed into law by the President, as of March 15, 2020, it seems likely that a […]
Read More
Contribution Health Logo

IRS Guidance on COVID-19 Expenses and HDHPs

On March 11, 2020, the IRS released Notice 2020-15 confirming that a plan that otherwise satisfies the requirements for a high deductible health plan (HDHP) can maintain HDHP status and preserve participant eligibility for tax-advantaged HSA contributions where the plan provides health benefits associated with COVID-19 testing and treatment prior to the deductible being satisfied […]
Read More

« Older Posts