This checklist is designed to help companies review the key reporting and notice requirements that may apply to their employer-sponsored group health plans under ERISA (the Employee Retirement Income Security Act). Please note that this list is for general reference purposes only and is not all-inclusive. Click to download entire checklist.
On Thursday, May 7, 2020, the United States Centers for Medicare and Medicaid Services (CMS) released the 2021 Notice of Benefit and Payment Parameters final rule. This rule finalizes the CMS’ proposed modification of existing policy relating to how pharmaceutical manufacturer direct assistance (i.e., coupons) accrues with respect to health plan enrollees’ annual limit on [...]
On May 4th, the Employee Benefits Security Administration (EBSA), a division of the Department of Labor, and the IRS filed a joint notice which extends numerous deadlines applicable to employee benefit plans that are subject to ERISA. Health and Human Services (HHS) concurred with the notice thus extending its parameters to non-federal governmental plans as [...]
The IRS released Notice 2020-23 on April 9, 2020, which postpones until July 15, 2020 the filing of many federal tax returns and the payment of taxes that had been due on or after April 1, 2020 and before July 15, 2020. Any tax return or payment due on or after April 1, 2020, and before [...]
The Families First Coronavirus Response Act (FFCRA) signed into law on March 18th included two temporary expanded paid leave options that are mandatory for employers with fewer than 500 employees. Additionally, there are tax credits available for employers that have paid employees with one of these two emergency leave provisions (outlined below). The chart below [...]
In light of the nation's response to COVID-19 and the resultant economic downturn, employers of all sizes face a dilemma of evaluating employee head counts. Many employers are considering furloughs or temporary layoffs to reduce immediate payroll, hoping the downturn lasts for a period of a few weeks instead of months. Below is a list [...]
The Department of Health and Human Services (HHS) and the Department of Labor (DOL) have issued adjusted/updated civil monetary penalties for a myriad of benefits related violations. The Departments are required by law to provide their annual adjustments by January 15th each year. The 2020 penalties will not be assessed until after January 15, 2020 [...]
New Jersey: Health Insurance Mandate In 2018, New Jersey Governor, Phil Murphy, signed into law The New Jersey Health Insurance Market Preservation Act. This law requires all New Jersey residents to have health insurance or pay a penalty. Lawmakers in New Jersey drafted this legislation in response to the decision to eliminate the ACA individual mandate with the [...]
Missing, incorrect, or late information regarding eligibility can lead to mistaken interpretation of coverage, no coverage/denied claims, or incorrect participant information. These can all lead to overbilling, underbilling, and claim payment errors. Additionally, eligibility errors can “over-obligate” the plan by allowing an invalid member to linger on the plan, for example: enrolling in COBRA for [...]
The newly created Massachusetts Department of Family and Medical Leave released updated draft regulations on March 29th for the new Paid Family and Medical Leave law. The Department will hold several listening sessions in May throughout the state before issuing final regulations sometime before July, 2019. Below is an outline of the draft regulations with pertinent [...]
