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If you are a large employer required to provide health plan coverage to avoid the employer mandate shared responsibility penalties, it is prudent to reevaluate your health plan contribution structure each year before open enrollment to ensure that your plan is still “affordable.”   Since the passage of the ACA, it is no longer a strategy to set ...

Last week Delta airlines announced it was going to begin charging employees enrolled in its health plan an extra $200 per month if they were not fully vaccinated.   Since that story made the news, we have received numerous inquiries from clients as to whether they could also charge employees more to be in their health plan.   The simple answer is yes, but ...

As discussed in our prior blog post, employer-sponsored health plans must soon provide pre-exposure prophylaxis (“PrEP”) drugs as a preventive service under the Affordable Care Act (“ACA”).  This means the HIV drugs must be offered at no cost to participants for all participants at risk for HIV exposure beginning in the 2021 plan year by ...

By: Lyndsey Barnett and Liam McMillin

The end of summer is (sadly) just around the corner. I know, it feels like we just finally got out of the house for the first time a week ago, but before we know it, the kids will be back in school, the days will start getting shorter, and the leaves will be changing colors.

As the summer ends, so do the COBRA premium ...

At the end of 2020, the No Surprises Act was enacted to provide protection against surprise medical bills.  Earlier this month, an interim final rule containing guidance for the new law was issued by Health and Human Services.  According to the release that accompanied the new guidance, under the new law, “Patient cost-sharing, such as ...

If you sponsor a self-insured group health plan (or a health reimbursement account), make sure you’ve set a calendar alert for July 31 to pay  the annual PCORI fee (Patient-Centered Outcomes Research Institute fee) for the 2020 plan year. The fee and the related IRS Form 720 are due no later than July 31st (note that July 31 falls on a Saturday in ...

The IRS has recently released the latest version of its correction program for retirement plans (referred to as EPCRS or Rev. Proc. 2021-30) that will make it easier for a plan sponsor to correct certain plan errors. One common error that can arise during the administration of a 401(k) plan is the improper exclusion of an employee from making ...

Today, in a 7-2 decision, the U.S. Supreme Court dismissed a challenge to the Affordable Care Act.  The decision leaves the law intact and allows approximately 31 million individuals to keep their coverage under the ACA.  The suit had been brought by several Republican-led states and the former Trump administration, and sought to have the entire ...

Earlier this week, the IRS issued Notice 2021-31 which provides some much sought after guidance on the new COBRA subsidy in the form of FAQs.  As part of this new guidance, the IRS provided some clarity on the definition of “involuntary termination” for purposes of eligibility for the subsidy. The guidance emphasizes the determination of an ...

The IRS released its annual inflation adjustment for Health Savings Accounts (HSAs) for 2022, the 2022 minimum deductible and maximum out-of-pocket limits associated with a high deductible health plan (“HDHP”), as well as the excepted benefit HRAs (EBHRAs) maximum for plan years beginning in 2022. For those already planning for next year ...

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