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 ...
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 ...