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COVID rules are confusing and ever-changing.  The CDC changes its mind so frequently on who and how to quarantine that the rules may change twice during your quarantine period and we are still waiting (as of the moment I am writing this at least) to see whether the Supreme Court is going to uphold the law on vaccine mandates (you can learn more about ...

We are in the middle of yet another COVID surge.  Testing sites have lines blocks long and at-home COVID tests are flying off the shelves as soon as the shelf is replenished.   In response to the latest surge, the Department of Labor, Health and Human Services, and the Treasury jointly released guidance yesterday that requires group health plans to ...

Since the start of the pandemic, there has been a swell of guidance that permits employers to revise their Section 125 plans (a/k/a Cafeteria Plans) to provide various relief to plan participants.   We previously blogged in detail about these changes that were permitted under the Coronavirus Aid Relief, and Economic Security Act (CARES Act)

As mentioned in our prior blog post, effective January 1, 2022 for calendar year plans, the ability of HSA plans to cover telehealth at 100% is ending.  If you have not already amended your plan to account for this expiration, you should do so now.  Any amendment will need to require plans to charge a reasonable fee for telehealth and apply any fees to ...

The IRS released its annual update for the cost-of-living adjustments for 2022. In contrast to the few changes made in the cost-of-living adjustments last year, there are widespread increases for 2022. As you can see from our chart below, almost all IRS limits were affected by this year’s cost-of-living adjustments, with the exception of ...

It is again time for plan sponsors to distribute their annual notices to participants. Outside of the normal changes to plan COLAs (which we expect to be announced anytime) and investment expense ratios, plan sponsors will want to consider and incorporate any changes made to their plan in the past year into this year’s annual notice. As a ...

Earlier this month, the US Department of Labor (“DOL”) issued a proposed rule that would reverse their own 2020 interpretation of the fiduciary investment rules.  The proposed rule would allow fiduciaries managing the investments for retirement plans to choose investments while also considering environmental, social, and governance ...

This week the DOL, IRS and HHS jointly issued FAQs regarding the rules surrounding when an employer can charge an unvaccinated worker more in its health plan.  This guidance doesn’t provide new information, but only confirms what most practitioners (including those at Graydon) have been advising – to charge a surcharge you must follow the ...

Last year the IRS provided guidance that permitted telehealth services to be offered under high-deductible health plans on a pre-deductible basis.  Plan sponsors were permitted to amend their plan documents so participants could receive telehealth services at no cost or at a cost less than the normal deductible. This meant those individuals ...

As discussed in our prior blog post, the No Surprises Act requires non-grandfathered group health plans offering coverage to disclose information regarding in-and out-of-network rates for certain covered items and services and prescription drugs in machine-readable files on a publicly available website. The machine-readable file ...

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