Effective January 1, 2022, the Connecticut Paid Leave law goes into full effect. Eligible employees may begin submitting claims in December for the January start date. The CT Paid Leave Authority is using the carrier AFLAC to determine eligibility, receive claims and make payment determinations. Below is an outline of the claims process which summarizes [...]
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The No Surprises Act which passed under the Consolidated Appropriations Act (“The Act”) includes many provisions that apply to group health plans which go into effect for plan years beginning on or after January 1, 2022. One such provision requires updated medical ID cards, however, guidance is not anticipated until sometime in 2022. In the [...]
The CARES Act created a temporary safe harbor that allows (but did not require) a HDHP health plan with a health savings account (HSA) to cover telehealth and remote care services prior to the member reaching their plan’s deductible. The CARES Act provision extended the safe harbor for plan years beginning on or before December 31, 2021. Members [...]
The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-36 which indexes the contribution percentages for 2022 for purposes of determining affordability of an employer’s plan under the Affordable Care Act (ACA). For plan years beginning on or after January 1, 2022, employer-sponsored coverage will be considered affordable if the employee’s required contribution for self-only coverage does [...]
On May 28, 2021, the Equal Employment Opportunity Commission (EEOC) posted updated and expanded guidance relating to COVID-19 and the workplace. According to the EEOC, federal laws prohibiting discrimination in the workplace “do not prevent an employer from requiring all employees physically entering the workplace to be vaccinated for COVID-19.” Specifically, the guidance addressed: Federal [...]
With the American Rescue Plan Act (ARPA) COBRA subsidy coming to end on September 30, 2021, questions are arising as to the plan administrators next steps. Below you will find some of the more common FAQs: Subsidy Expiration Notification To ensure compliance, plan administrators must provide a timely notice to those AEIs who wish to [...]
On June 17, 2021, the Supreme Court turned back a long-standing challenge to the Affordable Care Act (ACA) by dismissing the challenge that was brought by 18 states (California v. Texas). The court ruled that the states that brought the suit over the ACA did not have the standing to do so. Background: On December [...]
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 [...]
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 [...]