In May 2021, the Department of Health and Human Services reversed a Trump administration position on the ACA’s section 1557. Background Under section 1557, health plans are prohibited from discriminating on the basis of race, color, sex, national origin, age and disability. Under the ACA, the definition of sex was clarified to include discrimination on [...]
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In April, the DOL issued FAQs discussing the American Rescue Plan Act (ARPA) COBRA subsidy. The FAQs left many with questions that were not addressed in the DOL’s guidance. On May 18, 2021, the IRS issued its guidance in Notice 2021-31 and a series of 86 FAQs that solve many of the points left unanswered in the [...]
The Internal Revenue Service released its 2022 Health Savings Account Inflation Adjustment Limits. A comparison of the 2022 and 2021 limits are listed below. The ACA maximum out-of-pocket limits have also been adjusted. The ACA uses a different adjustment calculation than the IRS when setting H.S.A. limits year over year. 2022 2021 Change HDHP Minimum [...]
The Consolidated Appropriations Act of 2021 (CAA) that was passed on December 27, 2020 is known primarily for its third round of direct payment stimulus checks. However, there were additional health benefit related provisions including: (1) expanded relief for health and dependent care flexible spending arrangements; (2) new reporting requirements for commission and similar compensation; [...]
The Office of Civil Rights (OCR) has been made aware of postcards being sent to healthcare organizations informing the recipients that they are required to participate in a “Required Security Risk Assessment,” and they are being directed to send their risk assessment to the following URL below (DO NOT click on the link below or [...]
Early this month, the DOL issued the model notices to be used for the COBRA subsidy that is part of the American Rescue Plan Act (ARPA). In addition, the EBSA has issued FAQs that address some of the outstanding items surrounding the subsidy. This initial guidance does not include details on administering the employer tax credit [...]
Connecticut Democrats and Governor Ned Lamont have both put forth proposals that would levy an annual assessment on the state’s insurance carriers and self-funded plans. The Democratic plan includes a public insurance option for small employers (less than 50 employees) in the state and have recommended levying an assessment on the state’s insurance companies that [...]
Historically worker’s compensation does not cover community spread diseases (i.e., common cold/flu) because they generally cannot be tied back to a workplace. With the COVID-19 pandemic, some workers and workplaces have been deemed essential and present a unique problem when considering worker’s compensation coverage. As a result, some states recently have implemented amendments to their [...]
On March 30, 2021, the IRS, in its released Announcement 2021-7, notified taxpayers that personal protective equipment (PPE) purchased for the purpose of preventing the spread of COVID-19 are now to be treated as a covered medical care amount under Section 213(d) of the IRS code. This includes masks, hand sanitizer, disposable gloves and sanitizing wipes. [...]
On March 10th, the American Rescue Plan Act of 2021(ARPA) was passed by both chambers of Congress and is expected to be signed by the President this week. The Act addresses several COVID relief provisions including another round of direct stimulus payments, unemployment compensation payments continuation, COVID-19 vaccine funds, and extension of the paycheck protection [...]