REMINDER: PCORI Fees Due By July 31, 2020 Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2020 deadline for paying fees that fund the Patient-Centered Outcomes Research Institute (PCORI). As background, the PCORI was established as part of the Affordable Care Act (ACA) [Read More]
In Rev. Proc. 2020-32, the IRS released the inflation-adjusted amounts for 2020 relevant to HSAs and high deductible health plans (HDHPs). The table below summarizes those adjustments and other applicable limits. Out-of-Pocket Limits Applicable to Non-Grandfathered Plans The ACA’s out-of-pocket limits for in-network essential health benefits have also been announced and have increased for 2021. [Read More]
Carrier Premium Credits and ERISA Fiduciary Obligations Due to COVID-19 and state and local stay-at-home orders, utilization of group medical and dental insurance benefits is down. As a result, some carriers recently notified employers that they will be issued premium credits. When asking how these premium credits should be treated by the employer, we often [Read More]
As the country continues to feel the impact of the COVID-19 National Emergency declared by President Trump on March 13, 2020, the IRS has provided some much-needed guidance and relief for employees. On May 12, 2020, the IRS issued Notices 2020-29 and 2020-33, which, among other things, extend the claims period for health flexible spending [Read More]
Agencies Extend Deadline to Pay COBRA Premiums, Extend Certain Other ERISA and Internal Revenue Code Deadlines Due to COVID-19 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 [Read More]
On March 27, the President signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The CARES Act comes as a continued response to the Coronavirus 2019 (COVID-19) pandemic that is significantly impacting the United States. The Act is a $2.2 trillion economic package that is meant to stabilize individuals and employers, [Read More]
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 [Read More]
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 [Read More]
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 allow issuers to continue policies that do not meet ACA standards. The transition policy has been extended to [Read More]
As part of the Further Consolidated Appropriations Act, 2020 (the “Act”), Congress repealed Section 512(a)(7) of the Internal Revenue Code of 1986 (the “Code”). This Code section was added as part of the Tax Cuts and Jobs Act of 2017 (the “TCJA”) and resulted in an unrelated business income tax (UBIT) liability when a tax-exempt [Read More]