Posted on December 20, 2020 at 3:58 pm

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 […]

Posted on November 23, 2020 at 6:16 pm

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 […]

Posted on September 1, 2020 at 12:50 pm

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 […]

Posted on May 20, 2020 at 5:20 pm

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 […]

Posted on April 7, 2020 at 7:21 pm

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 […]

Posted on March 16, 2020 at 12:03 am

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 […]

Posted on March 13, 2020 at 1:31 pm

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 […]

Posted on January 14, 2020 at 2:21 pm

Fourth Circuit affirms Plan Administrator’s Status as ERISA Fiduciary in Life Insurance Case  In a recent appeal, Dawson-Murdock v. National Counseling Group, Inc., the Fourth Circuit Court of Appeals vacated a lower court’s dismissal of a claim by a deceased employee’s spouse against an employer for breach of fiduciary duty under ERISA in administering a […]

Posted on December 17, 2019 at 7:12 pm

Effective January 1, 2020, many employers will have the option of offering individual coverage HRAs (“ICHRAs”) to reimburse employees for individual health insurance coverage.  ICHRAs allow employers to satisfy the Affordable Care Act (“ACA”) mandate to offer health insurance to full-time employees in a manner distinct from sponsoring traditional insured or self-funded group health coverage.  […]

Posted on October 22, 2019 at 6:26 pm

A recent court decision calls into question the Department of Labor’s 2018 final rule on association health plans (“AHPs”).  On March 28, 2019, the United States District Court for the District of Columbia found that the rule’s interpretation of the term “employer” unreasonable and invalidated several components of the previously issued rule, a rule which […]