The impacts of the COVID-19 National Emergency, as declared by President Trump on March 13, 2020, have been vast. As a result, many employers and employees are struggling to meet their various filing, notice, election, or other deadlines. In order to ease this burden on employers, plans and participants, on April 28, 2020, the Department of Labor (DOL), the Internal Revenue Service (IRS), and Department of Health and Human Services (HHS) issued much needed guidance and relief. Notably, the guidance requires employers and plans to suspend the deadline for qualified beneficiaries to elect COBRA or pay COBRA premiums from March 1, 2020 until 60 days after the National Emergency ends (or such other date as specified by the Agencies)
DOL Relief for Group Health Plans and Disability and Other Welfare Plans
EBSA Disaster Relief Notice 2020-01, eases the burden for group health plans, disability plans, and pension plans to provide notices and disclosures required under ERISA and Internal Revenue Code of 1986 (the “Code”) by clarifying, among other things, that:
EBSA Notice 2020-01 also includes general ERISA fiduciary compliance guidance, asking plans to “act reasonably, prudently, and in the interest of the covered workers and their families who rely on their health, retirement, and other employee benefit plans for their physical and economic well-being.” The DOL requests that plans make reasonable accommodations to prevent the loss of benefits or undue delay in paying benefits.
Finally, the Notice clarifies that relief may be further extended in specific regions of the country if there are different outbreak period end dates for different parts of the country.
Relief for Participants and Beneficiaries
In order to ease the burden on participants and beneficiaries, the DOL, in coordination with the IRS issued a Final Rule extending certain timeframes and deadlines for participants to consider coverage elections and benefits decisions under ERISA and the Code.
Specifically, Final Rule provides plan participants, beneficiaries, qualified beneficiaries, and claimants with relief from meeting the below referenced periods and dates during the period of March 1, 2020 until 60 days after the announced end of the COVID-19 National Emergency (or such other date announced by the Agencies in a future notice):
Consistent with the above, the Final Rule provides group health plans with relief from issuing COBRA election notices for any qualifying event that occurred between March 1, 2020, and 60 days after the announced end of the COVID-19 National Emergency (or such other date announced by the Agencies in a future notice).
Neither the Final Rule nor EBSA Notice 2020-01, provide guidance regarding the applicable PCORI fee amount for plan years ending after October 1, 2019, extend the PCORI fee deadline (currently July 31, 2020), or modify permitted cafeteria plan election changes.
Employers are encouraged to familiarize themselves with the relief in the Final Rule and EBSA Notice 2020-01, work with their insurance broker, COBRA administrator or other vendors to ensure compliance with this relief, and continue to work with their employees during this difficult time.
The information provided in this alert is not, is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers or our clients. This is not legal advice. No client-lawyer relationship between you and our lawyers is or may be created by your use of this information. Rather, the content is intended as a general overview of the subject matter covered. This agency and Marathas Barrow Weatherhead Lent LLP are not obligated to provide updates on the information presented herein. Those reading this alert are encouraged to seek direct counsel on legal questions.
© 2020 Marathas Barrow Weatherhead Lent LLP. All Rights Reserved.
COVID-19 has brought many new challenges to the way we communicate with our coworkers, friends and family. Never has listening been more important than it is right now. As we focus on listening fully, listening with focus and listening with the true intent to understand and not just hear, the common threads we are hearing from employees are paving the way for the next developments in your wellbeing programs. Please continue to keep in touch on the needs and concerns of your teams and we will do our best to work with you on solutions.
Have a safe and healthy week!
Career Wellbeing |
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Social & Family Wellbeing |
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Financial Wellbeing |
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About the Author
Andrea Davis, Director of Wellbeing
Andrea joined Alera Group Northeast (formerly CBP) in July 2013, bringing over 15 years of experience in management consulting and strategic solutions. As the Director of Wellbeing, she is responsible for assisting with the development, implementation and evaluation of comprehensive wellness strategies for existing and prospective Alera Group clients. She provides assistance and support to Alera Group clients by developing personalized programs that fit clients’ unique health management needs, wellness program implementation, committee development, promotion and marketing of their programs to encourage participation. In addition, Andrea conducts program analysis and generates reports related to program participation, health assessment and client utilization.
This legal alert was updated May 13, 2020.
A cafeteria plan, or Section 125 plan, sometimes referred to as a POP plan, allows employees to pay for certain expenses on a pretax basis. Employees choose between a taxable benefit (cash, typically distributed via payroll) and two or more pre-tax qualified benefits. Just like standing in line at a cafeteria and selecting a salad, a plate of meatloaf, and a carton of milk, employees can “stand in line” and select health insurance, vision insurance, and dental insurance – and more! The IRS limits the benefits that can be offered through a cafeteria plan.
Employees can make elections and select which of the offered benefits they would like to enroll in. Employees can choose to cover other individuals, including spouses and dependents, if the employer’s plan allows. These elections are prospective, with an exception for birth, adoption and placement for adoption as well as new hires, when the employer’s plan does not impose a waiting period for new employees. The IRS considers pretax elections to generally be irrevocable unless a permitted event occurs or there is an exception. These events sometimes overlap and fall into three general categories, HIPAA special enrollment events, change in status events, and other triggering events.
A plan sponsor is not required to recognize any midyear changes to pretax elections. However, for practical purposes, because HIPAA requires group health plans to provide a special enrollment opportunity to an employee upon the occurrence of specific events (e.g. marriage, birth, adoption, etc.)¹ most plan sponsors at a minimum will design their plan to recognize HIPAA special enrollment events, permitting changes to pretax elections midyear. All of the events however are optional, and a plan sponsor must ensure their plan documents affirmatively indicate which of the events are recognized.
QUALIFYING EVENTS |
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Gain dependent(s) due to marriage |
Employee or dependent becomes entitled to Medicare or Medicaid |
Employee/dependent status change results in gaining eligibility under the plan (e.g., new job; part-time to full-time) |
Plan makes SIGNIFICANT cost change |
Plan makes automatics small cost change(s) |
Lose spouse (e.g., divorce, legal separation, death of spouse) |
Employee or dependent becomes entitled to premium assistance subsidy for Medicaid or CHIP |
Employee/dependent employment change results in losing eligibility under employer plan (e.g., full to part-time; unpaid leave) |
Plan makes SIGNIFICANT curtailment in coverage |
Other employer's plan increases/decreases/ceases coverage |
Gain/lose child (e.g., birth adoption or placement for adoption/death) |
Employee or dependent loses entitlement for Medicare, Medicaid, or CHIP |
Employee hours of reduced to average less than 30 hours a week |
Plan eliminates/adds new benefit or coverage option |
Other employer's plan offers open enrollment |
Dependent loses/gains eligibility (e.g., child reaches age limit/becomes student after age 26) |
Change in residence triggers gain/loss eligibility (e.g., move in/out of a plan services area |
Employee becomes eligible to enroll in a QHP in the Marketplace |
Order requiring plan to add child(ren) to health plan coverage |
Order requiring another employer's plan to add child(ren) to health plan coverage |
The following situations are not cafeteria plan qualifying events:
On May 12, 2020, the IRS issued Notice 2020-29 which, among other things, allow employees to amend their cafeteria plans to permit employees to make mid-year changes for the following purposes:
Notice 2020-29 provides that employers may amend their plans to allow each eligible employee to make prospective election changes or an initial election regardless of whether the election change satisfies one of the permitted election changes under applicable Treasury regulations. The Notice is very clear that this is not a free-for-all. The employer has the discretion to impose parameters for these election changes, including the extent to which the election changes are permitted and applied, and they can limit the period during which election changes may be made.
The relief may be applied retroactively to January 1, 2020; however, as set forth above, all election changes must be prospective. The retroactive application of the relief is to cover any employer who may have allowed an election change that may not have been consistent with Section 125 (but would be consistent with one of the permitted election changes discussed above).
Finally, employers must ensure the election changes do not result in failure to comply with the nondiscrimination rules. The Notice provides strategies an employer may use to ensure there is no adverse selection of health coverage, such as limiting elections to circumstances in which an employee’s coverage will be increased or improved as a result of the election change (ex. switching from self-only to family coverage).
For more COVID-19 legal alerts, please visit our resource center at aleragroup.com/coronavirus/#legalalerts.
If you have any questions related to this alert, please reach out to your Alera Group advisor or email us at info@aleragroup.com to be connected with your local firm.
¹Special Enrollment rights are not required for “HIPAA-excepted benefits” which generally include stand-alone dental, vision and most health care FSAs.
The information contained herein should be understood to be general insurance brokerage information only and does not constitute advice for any particular situation or fact pattern and cannot be relied upon as such. Statements concerning financial, regulatory or legal matters are based on general observations as an insurance broker and may not be relied upon as financial, regulatory or legal advice. This document is owned by Alera Group, Inc., and its contents may not be reproduced, in whole or in part, without the written permission of Alera Group, Inc. Reviewed as of 05/13/2020.
Notice for Individual, Small Group and Student Blanket Comprehensive Health Insurance Policies
Dear Policyholder,
A recent Executive Order issued by Governor Cuomo, together with recent amendments to the insurance and banking regulations (the “regulations”) issued by the New York State Department of Financial Services (“Department”), extend grace periods and give you other rights under certain health insurance policies if you are a policyholder of an individual, small group or student blanket comprehensive health insurance policy and can demonstrate financial hardship as a result of the novel coronavirus (“COVID‑19”) pandemic. A “small group” means a group of one hundred or fewer employees or members exclusive of spouses and dependents. These grace periods and rights are currently in effect but are temporary, though they may be extended further. Please check the Department’s website at https://www.dfs.ny.gov/consumers/coronavirus for updates.
Insurance Payments – Grace Period
If you can demonstrate financial hardship as a result of the COVID-19 pandemic, your insurer must extend to the applicable grace period for the payment of premiums to the later of the expiration of the applicable contractual grace period and 11:59 p.m. on June 1, 2020, for any individual, small group or student blanket comprehensive health insurance policyholder. Your insurer is responsible for the payment of claims during such period and may not retroactively terminate your policy for non-payment of premium. In addition, if you do not make a timely premium payment and can demonstrate financial hardship as a result of the COVID-19 pandemic, your insurer may not impose any late fees relating to the premium payment, report you to a credit reporting agency or a debt collection agency regarding such premium payment and provide information to you regarding alternative policies available from such insurer and provide contact information for the NY State of Health.
How to Demonstrate Financial Hardship
If you are unable to make a timely premium payment due to financial hardship as a result of the COVID-19 pandemic, you may submit to your insurer a statement that you swear or affirm in writing under penalty of perjury that you are experiencing financial hardship as a result of the COVID-19 pandemic, which the insurer or premium finance agency, as applicable, shall accept as satisfactory proof. Such statement is not required to be notarized.
Questions
If you have any questions regarding your rights under the Executive Order or regulations, please contact your insurer, broker, or premium finance agency.
As we all adapt to new rhythms of working from home and social distancing, it's important that we stay on top of our wellbeing. Each week we're putting together a fresh list of wellbeing resources that target reach of the six categories of holistic wellbeing: career, social, financial, emotional physical and community. We hope you enjoy this week's list!
Career Wellbeing |
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Social & Family Wellbeing |
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Financial Wellbeing |
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Physical Wellbeing |
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Emotional Wellbeing |
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Community Wellbeing |
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EMPLOYER FOCUSED RESOURCES |
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About the Author
Andrea Davis, Director of Wellbeing
Andrea joined CBP, an Alera Group company, in July 2013, bringing over 15 years of experience in management consulting and strategic solutions. As the Director of Wellbeing, she is responsible for assisting with the development, implementation and evaluation of comprehensive wellness strategies for existing and prospective CBP clients. She provides assistance and support to CBP clients by developing personalized programs that fit clients’ unique health management needs, wellness program implementation, committee development, promotion and marketing of their programs to encourage participation. In addition, Andrea conducts program analysis and generates reports related to program participation, health assessment and client utilization. She interfaces with CBP’s Chief Medical Officer, Dr. Terrence Fitzgerald, to leverage clinical and analytic data in support of CBP’s health management solutions.
This article was adapted from the COVID-19 in the Construction Industry webinar on April 9, 2020.
To watch the full webinar, click here.
During the COVID-19 outbreak, when it may not be possible to eliminate the hazard, the most effective protection measures are engineering controls, administrative controls, safe work practices, and personal protective equipment (PPE).
Engineering Controls
► Installing high-efficiency air filters.
► Increasing ventilation rates in the work environment.
► Installing physical barriers, such as clear plastic sneeze guards.
► Installing a drive-through window for customer service.
Administrative Controls
► Encouraging sick workers to stay at home
► Minimizing contact among workers, clients, and customers by replacing face-to-face meetings with virtual communications and implementing telework if feasible.
► Establishing alternating days or extra shifts that reduce the total number of employees in a facility at a given time, allowing them to maintain distance from one another while maintaining a full onsite work week.
► Discontinuing nonessential travel to locations with ongoing COVID-19 outbreaks. Regularly check CDC travel warning levels at: www.cdc.gov/coronavirus/2019-ncov/travelers.
► Developing emergency communications plans, including a forum for answering workers’ concerns and internet-based communications.
► Training workers who need to use protecting clothing and equipment how to put it on, use/wear it, and take it off correctly, including in the context of their current and potential duties. Training material should be easy to understand and available in the appropriate language and literacy level for all workers.
Safe Work Practices
► Providing resources and a work environment that promotes personal hygiene. For example, provide tissues, no-touch trash cans, hand soap, alcohol-based hand rubs containing at least 60 percent alcohol, disinfectants, and disposable towels for workers to clean their work surfaces.
► Requiring regular hand washing or using of alcohol-based hand rubs. Workers should always wash hands when they are visibly soiled and after removing any PPE.
► Post handwashing signs in restrooms.
Personal Protective Equipment (PPE)
Examples of PPE include: gloves, goggles, face shields, face masks, and respiratory protection, when appropriate. All types of PPE must be:
► Selected based upon the hazard to the worker.
► Properly fitted and periodically refitted, as applicable (e.g., respirators).
► Consistently and properly worn when required.
► Regularly inspected, maintained, and replaced, as necessary.
► Properly removed, cleaned, and stored or disposed of, as applicable, to avoid contamination of self, others, or the environment.
To watch the full webinar, click here. For more information on COVID-19, check out our live dashboard at aleragroup.com/coronavirus.
If you have any questions about the content and resources provided in the webinar above, please contact jsimmers@hmk-ins.com.
About the Author:
Jade Simmers
Director of Risk Management
HMK Insurance, an Alera Group Company
Jade Simmers joined HMK Insurance in January of 2018 to begin the HMK Risk Management Department. Jade has 25 years of experience in Health & Safety/Risk Management and has worked in both the fields of construction and general industry. Jade has been working in the insurance industry for the last eight years and has worked for both insurance carriers and brokers. In his current role, he works with HMK commercial clients to assess, address, and mitigate safety-related and OSHA-regulated hazards. To HMK clients, Jade has provided regulatory programs & training, job-site & facility hazard inspections, safety committee facilitation, accident investigation, and on-call consulting. Jade actively participates in the Eastern Pennsylvania Chapter of ABC and the Lehigh Valley Safety Committee, where he is frequently a guest speaker. Jade is an OSHA Outreach trainer for both the Construction & General Industry and holds an Advanced Safety Certificate with the National Safety Council.
This content was last reviewed on April 14, 2020.
Employers who are uncertain about how to calculate their qualified health plan expenses and qualified leave wages should consult with their legal counsel or financial adviser.
The Families First Coronavirus Response Act (“FFCRA”) created two new refundable tax credits intended to reimburse employers for costs associated with their financial obligations to provide leave benefits created by the Act plus the cost of continuing health insurance for employees on FFCRA leave.
Employers with fewer than 500 employees (“eligible employers”) are entitled to receive a credit in the full amount of the qualified sick leave wages and qualified family leave wages, plus allocable qualified health plan expenses and the employer’s share of Medicare tax, paid for leave during the period beginning April 1, 2020, and ending December 31, 2020.
Determining what is meant by “costs associated” and to understand what is included in the tax credits, the DOL’s guidance references the Internal Revenue Code.
In general, the term “group health plan” as defined in Section 5000(b)(1) includes all plans that are subject to continuation coverage under COBRA, such as medical, dental, vision, health FSA and HRA.
However, the provisions related to determining which contributions by an employer to these health plans are allowed to be included for purposes of claiming payroll tax credits and the extent these amounts are excluded from the gross income of employees under Section 106(a) of the Code is not black and white.
These are complicated issues and determining the deductible costs is not easy. Therefore, we recommend employers who are uncertain should reach out to their legal counsel or qualified accountant for guidance.
For more legal alerts and resources, please visit our live COVID-19 dashboard.
The information contained herein should be understood to be general insurance brokerage information only and does not constitute advice for any particular situation or fact pattern and cannot be relied upon as such. Statements concerning financial, regulatory or legal matters are based on general observations as an insurance broker and may not be relied upon as financial, regulatory or legal advice. This document is owned by Alera Group, Inc., and its contents may not be reproduced, in whole or in part, without the written permission of Alera Group, Inc.
To be eligible for benefits, three criteria must be met:
Employer must have work for the employee;
Employer and employee must agree on a work schedule;
Joey works in a coffee shop. The shop is closed for business. It doesn’t matter if it is due to a lack of business or to a shutdown order closing all restaurants. Since there is no work for Joey, he may be eligible for unemployment insurance, but he is not eligible for EPSLA or EFMLEA.
Alicia is an attorney working for a law firm. The office is closed, but everyone is teleworking from home. Alicia and her employer agree she can work whenever she wants, except that they want her to work from 9 to 5 on Tues. and Thurs., so she is available for clients. All her other work can be in the evenings, weekends or whenever she wants. Since Alicia did not have an income loss, she does not need either EPSLA or EFMLEA benefits.
Mary works as a grocery store cashier, an essential business. The store is open from 8 AM to 10 PM daily and Mary is offered 40 hours per week in work. Her normal rate of pay is $15.00 per hour. Mary has an autoimmune disease and a compromised immune system. Her doctor tells her that she is at high risk and that she must self-quarantine. Since work is available, but due to the self-quarantine order, Mary is eligible for benefits under the EPSLA. Here benefits are calculated as follows: $15/hour X 40 hours X 100% benefit = $561 maximum weekly benefit *Since Mary does not have a child, she is not eligible for EFMLEA benefits.
George is Alicia’s husband. He works making medical equipment in a factory. His employer is open, and his work hours are from 9 to 5, Monday to Friday. Since Alicia must work during the day on Tues. and Thurs., George applies for leave on those days so he can take care of their 7-year-old daughter Cindy, whose school is closed due to COVID-19. George applies for and is approved for two days of leave since he must care for their daughter. George makes $20 per hour, is approved for 16 hours of leave per week and receives 2/3 of his wage as EPSLA and then EFMLEA benefits. $20/hour X 16 hours X 2/3 benefit = $266.80 weekly benefit.
For more related updates, check out our COVID-19 dashboard for our latest updates and legal alerts.
This document was created by Alera Group, Inc. Updated as of 4/6/2020. This is not legal advice. No client-lawyer relationship between you and our lawyers is or may be created by your use of this information. Rather, the content is intended as a general overview of the subject matter covered. To be eligible for benefits, three criteria must be met: 1. Employer must have work for the employee; 2. Employer and employee must agree on a work schedule; 3. Employee must have a qualifying reason (see FFCRA FAQs for details)
Amid the economic crisis brought on by the COVID-19 pandemic, many small businesses are devoting most of their attention to finances — and with good reason. The disruption caused by the pandemic threatens their very existence.
So the questions insurance agents are hearing most often these days from small-business owners are:
But in the rush to secure funding to keep their operation running and their employees on the payroll, some businesses are paying too little attention to another potentially fatal risk: cyber attack.
With unprecedented numbers of people working remotely due to the pandemic and more business than ever being transacted online, cyber criminals are recognizing vulnerabilities and exploiting them.
As Alera Group notes in the recently released document Warning: Cyber Liability — Increase Risk with COVID-19:
"Experts are projecting a 30-40 percent increase in cyber attacks during the novel coronavirus pandemic. This is primarily due to hackers exploiting the vulnerabilities associated with this crisis, especially those arising from employees working from home. In situations such as these, companies need to reexamine their network security infrastructure and Cyber Liability Insurance program."
To view the full, single-page document, click on the image at right.
While seeking information on financial assistance and insurance coverage, business owners have another priority that may compromise their cyber security: keeping their remote workforce as productive as possible.
"What's happening on the cyber security side is that people's guards are down," Asaf Lifshitz, CEO of Massachusetts and Israel-based Sayata Labs, tells the publication Insurance Business America. “Cyber security almost always comes at some degree of conflict with productivity, and all of a sudden [as a result of the coronavirus] there’s this massive shortage of productivity. Companies need to be able to transact business, now that their employees are working from home and they’re already taking a hit.
“In times like these, IT managers have to make compromises. Ideally, we’d like our employees to log in via a VPN, or to conform to whatever standards we put in place before. Now, it’s much harder to enforce. If we insist on doing it, productivity will take a bigger hit, and so those constraints are relaxed a little bit — and that’s what I mean when I say guards are down from a pure cyber security perspective."
The Conversation website explores the risks of using popular online collaboration tools such as Zoom and Slack in its piece Working from home risks online security and privacy— how to stay protected. The piece includes these risk management tips:
Be careful what you post publicly. Check that there is no potentially sensitive information in it. Once it’s published online, it’s there, forever.
Check recent security and privacy reports about online collaboration tools before using them, and if in doubt, consult your employer. These tools can have access to details about your devices, your data and your video and audio conversations. The Electronic Frontier Foundation is a good source.
Protect your devices. Install anti-virus software, update systems and apps, implement multi-factor authentication (so that multiple pieces of evidence are needed for someone to use your login, such as username and password and a text message), and be on the lookout for phishing scams.
Zoom Bombing and other forms of hijacking meetings can be prevented. Share meeting links with only invited parties. Configure Zoom to only allow the host to share screen, as appropriate. And disable file transfers to stop trolls sharing viruses to all attendees.
While good risk management is always advisable, it's also true that cyber breaches are inevitable. As I've written before, "Because no business is immune to cybercrime, it stands to reason that every business should protect itself with cyber insurance. Competitive pricing among the broad array of carriers offering coverage further contributes to the value of a cyber policy."
For more information on cyber insurance, see the Alera Group flier. And if you'd like to know more about how cyber insurance can protect your business, contact us at info@aleragroup.com to be connected with an expert.
About the Author:
Andrew Armstrong
Partner/Account Executive
Sylvia Group, an Alera Group Company
The fourth generation in his family to provide clients with custom-designed solutions to risk-mitigation challenges, Andrew Armstrong carries on the Sylvia Group tradition of service to his clients and community. A Certified Commercial Lines Professional (CCLP), he makes sure that no detail related to a business' insurance needs goes overlooked. Through an open discussion of their needs and budget, he works with clients to design coverage programs in a collaborative process that leaves them feeling better for the experience.
The passing of the CARES Act and $350 billion Paycheck Protection Program (PPP) created extensive financial assistance to help businesses continue operating and enable employees to retain their jobs. It also created endless questions about eligibility for loans and grants, and about compliance with employee benefits regulations.
One of the CARES ACT-related questions we've received is, "Am I eligible for assistance as a sole proprietor?"
The U.S. Small Business Administration (SBA) addresses this on its website:
"The SBA’s Economic Injury Disaster Loan provides vital economic support to small businesses to help overcome the temporary loss of revenue they are experiencing as a result of the COVID-19 pandemic.
"This program is for any small business with less than 500 employees (including sole proprietorships, independent contractors and self-employed persons), private non-profit organization or 501(c)(19) veterans organizations affected by COVID-19."
Recognizing that not all questions are as easy to answer as the one about the eligibility of sole proprietors, Alera Group has established a webinar series to address employers' concerns regarding COVID-19.
The webinars feature specialized advisers who provide updates and explanations on legislation and compliance issues, and they include the opportunity to submit viewer questions. Upcoming are:
For further details and registration, click on the corresponding link above.
Within a day or two of each webinar, Alera Group will post a recording of the session in its Coronavirus Resource Center. Comprehensive and easy to navigate, the attractively designed page also includes links to Property & Casualty Insurance information, legal alerts, employer resources, FAQs, wealth management resources and infographics such as this Decision Tree for Emergency Paid Sick Leave (EPSLA).
If you have any questions about our COVID-19 resources and updates, please reach out by emailing info@aleragroup.com.
About the Author
Maureen Armstrong
Managing Partner at Sylvia Group, an Alera Group Company
In a career spanning three decades, Maureen Sylvia Armstrong has been an established business and civic leader in Southeastern Massachusetts. It’s a reflection of Maureen’s vision, dedication and inexhaustible drive that Sylvia Group’s reputation for expertise and superior customer service in insurance, employee benefits and financial planning is matched only by its widely recognized commitment to the community of SouthCoast and beyond.
The information contained herein should be understood to be general insurance brokerage information only and does not constitute advice for any particular situation or fact pattern and cannot be relied upon as such. Statements concerning financial, regulatory or legal matters are based on general observations as an insurance broker and may not be relied upon as financial, regulatory or legal advice. This document is owned by Alera Group, Inc., and its contents may not be reproduced, in whole or in part, without the written permission of Alera Group, Inc.