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Legal Alert: Collecting Premiums During Employee’s Leave of Absence

When an employee takes an unpaid leave of absence, the question arises on how an employer should collect benefit premium payments to continue benefits during that time. The only regulatory guidance on this comes from the original Family and Medical Leave Act (FMLA) regulations. Following those, employers have three choices, they can utilize just one …

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Legal Alert: Notice Requirements When Making Health Plan Design Changes

As employers work to stay financially solvent during the COVID-19 pandemic, many are looking to change their health plan designs in order to ensure employees have access to the care they need while balancing the financial impact on the business. The type of change contemplated dictates when notice must be given to employees. Type of …

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Legal Alert: Dependent Care Assistance Programs & COVID-19

In the wake of the COVID-19 pandemic, many employers are dealing with how to handle Dependent Care Assistance Programs (DCAPs) when employees are no longer working and not in need of childcare, or alternatively, an employee’s childcare program/center/provider has closed due to the pandemic. DCAPs, sometimes referred to as “dependent flex spending accounts” are an …

Read moreLegal Alert: Dependent Care Assistance Programs & COVID-19

Legal Alert: Dependent Care Assistance Programs & COVID-19

In the wake of the COVID-19 pandemic, many employers are dealing with how to handle Dependent Care Assistance Programs (DCAPs) when employees are no longer working and not in need of childcare, or alternatively, an employee’s childcare program/center/provider has closed due to the pandemic. DCAPs, sometimes referred to as “dependent flex spending accounts” are an …

Read moreLegal Alert: Dependent Care Assistance Programs & COVID-19

Congress Passes Families First Coronavirus Response Act

On March 18, Congress passed, and President Trump signed into law, the Families First Coronavirus Response Act (FFCRA). The FFCRA is a bipartisan effort to help employers and individuals alike in managing pay, benefits, and business considerations during the COVID-19 pandemic. The focus of this alert is the impact of FFCRA on employer-sponsored benefits and …

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Offering Telehealth to Employees Not Eligible for Group Health Plans

Many employers that sponsor group health plans have portions of their employee population that are not eligible for the group health plan, typically because they are part-time employees. Employers sometimes wish to give these part-time employees something to assist them with their health care needs or expenditures, and it can be tempting to offer that …

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COVID-19 Update Employee Terminations, Furloughs, and Lay-offs: COBRA, Reinstatement, and Closed Businesses

As much of the country is locked-down due to coronavirus 19 (COVID-19), employers have concerns regarding their employee benefit programs. This may stem from a reduction in hours and, unfortunately, from terminating, furloughing, or laying-off employees – at least temporarily. The following are considerations for employers when addressing employees’ benefits during a layoff or other …

Read moreCOVID-19 Update Employee Terminations, Furloughs, and Lay-offs: COBRA, Reinstatement, and Closed Businesses

Information for Employers and Group Health Plan Sponsors on COVID-19

States and the federal government have issued (or re-issued) guidance for employers in response to the recent novel coronavirus disease 2019 (COVID-19) pandemic. As of March 14, 2020, the Centers for Disease Control and Prevention (CDC) has reported more than 2,000 cases from 49 states and Washington, DC.  Agency guidance includes the following: Internal Revenue …

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CMS Extends Transition Relief for Non-Compliant Plans through 2021

On January 31, 2020 the Centers for Medicare & Medicaid Services (CMS) announced a one-year extension to the transition policy (originally announced November 14, 2013 and extended six times since) for individual and small group health plans that allows issuers to continue policies that do not meet ACA standards.  The transition policy has been extended to …

Read moreCMS Extends Transition Relief for Non-Compliant Plans through 2021