July Business Services
|
Pollard & Associates
|
Great Lakes Pension Associates, Inc.
|
Retirement Planners and Administrators (RPA)
|
Regional Sales Director (West) July Business Services
|
Defined Contribution Account Manager Nova 401(k) Associates
|
Retirement Solutions Specialists
|
Fringe Benefit Group
|
TPA Retirement Plan Consultant EPIC RPS (TPA/DPS)
|
July Business Services
|
Greenline Wealth Management
|
Senior Specialist 401k Recordkeeping T Bank N.A.
|
New York City District Council of Carpenters Benefit Funds
|
Defined Contributions Compliance Consultant Loren D. Stark Company (LDSCO)
|
“BenefitsLink continues to be the most valuable resource we have at the firm.”
-- An attorney subscriber
Physician with Long COVID Wins Claim Seeking Long-Term Benefits
DeBofsky Law Apr. 12, 2024 "The ruling offers a lesson to claimants on how to prove a disability claim involving long COVID, but also teaches insurers what not to do.... Although the court ... acknowledged that Unum may have had some basis for questioning Abrams' claim due to the absence of definitive objective test results, the court was convinced by the consistency of the medical findings presented." [Whitehouse v. Unum Life Ins. Co. of America, No. 22-1736 (D. Minn. Mar. 21, 2024)] Tags: COVID-19 • Disability Plans |
CDC Issues New COVID-Related Guidance: What This Means for Employers
Mintz [Guidance Overview] Mar. 27, 2024 "While the new guidance provides some clarity on when employees with COVID and other respiratory viruses can return to work, employers will continue to grapple with ... COVID-related issues ... [such as] managing employees' requests for time off when experiencing active symptoms of a respiratory virus ... Employers must also be aware of other federal and state-specific guidance related to COVID-19.... In New York State, the COVID-19 Sick Leave Law that went into effect in 2020, [has yet] to be rolled back or modified." Tags: COVID-19 • FMLA and Other Leave |
The CARES Act Paid Leave Door May Be Open, But the Path to Recovery Remains Narrow and Uncertain for Most Government Contractors
Miller & Chevalier Mar. 1, 2024 "[M]ost federal contractors know that it can be challenging to recover increased costs for paid leave stemming from the COVID-19 pandemic under Section 3610 of the [CARES] Act.... A recent Armed Services Board of Contract Appeals (ASBCA) decision provides claimants with some reason for hope by confirming that the ASBCA has Contract Disputes Act (CDA) jurisdiction over appeals from a contracting officer's denial of Section 3610 claims.... [E]stablishing jurisdiction is only the first step, and the path to recovering paid leave costs remains narrow and highly dependent on the facts of each case." Tags: CARES Act • COVID-19 • FMLA and Other Leave |
Text of IRS Publication 969: Health Savings Accounts and Other Tax-Favored Health Plans (PDF)
Internal Revenue Service [IRS] [Official Guidance] Feb. 8, 2024 23 pages; Rev. Jan. 5, 2024. "For use in preparing 2023 returns.... What's New: ... Notice 2023-37 addresses the announced end of the COVID-19 public health emergency and the National Emergency Concerning the Novel Coronavirus Disease 2019 Pandemic ... Notice 2023-37 also clarifies whether certain items and services are treated as preventive care under section 223(c)(2)(C)." Tags: COVID-19 • Cafeteria Plans • HSAs • Health Plan Information for Employees |
Draft IRS Publication 969: Health Savings Accounts and Other Tax-Favored Health Plans (PDF)
Internal Revenue Service [IRS] [Official Guidance] Feb. 7, 2024 24 pages; Feb. 6, 2024. "For use in preparing 2023 returns.... What's New: ... Notice 2023-37 addresses the announced end of the COVID-19 public health emergency and the National Emergency Concerning the Novel Coronavirus Disease 2019 Pandemic ... Notice 2023-37 also clarifies whether certain items and services are treated as preventive care under section 223(c)(2)(C)." Tags: COVID-19 • Cafeteria Plans • HSAs • Health Plan Information for Employees |
Court Awards Minimal ERISA Penalties for Plan's Failure to Furnish Documents During COVID-19
Thomson Reuters Practical Law Feb. 6, 2024 "In determining whether ERISA penalties should be awarded, the district court grouped the claimant's requested documents by category, which it analyzed in turn.... In a ruling that was largely favorable to the employer/plan sponsor, the district court in this case expressly referenced the [DOL's] COVID-related 'outbreak period' rules -- which suspended the deadlines for some plan compliance obligations." [Zavislak v. Netflix, Inc., No. 21-1811 (N.D. Cal. Jan. 31, 2024)] Tags: COVID-19 • Health Plan Administration |
Philadelphia COVID-19 Paid Sick Leave Ordinance Ending
OneDigital Dec. 21, 2023 "The COVID-19 Paid Sick Leave Ordinance, which requires [businesses with 25 or more employees] to provide up to 40 hours of additional paid sick leave to eligible employees when they are unable to work for certain COVID-19 reasons, will expire on December 31, 2023. However, covered employers will still be required to keep all compliance records for this law for two years (through December 31, 2025)." Tags: COVID-19 • FMLA and Other Leave • Local Regulation |
Philly's Paid Sick Leave Law for COVID-19 Ends December 31
Philly Voice Dec. 13, 2023 "A city rule that requires employers to provide up to 40 hours of additional compensated time off for the sickness expires on New Year's Eve." Tags: COVID-19 • FMLA and Other Leave • Local Regulation |
Text of Draft IRS Publication 969: Health Savings Accounts and Other Tax-Favored Health Plans (PDF)
Internal Revenue Service [IRS] [Official Guidance] Dec. 7, 2023 "For use in preparing 2023 returns.... What's New: ... Notice 2023-37 addresses the announced end of the COVID-19 public health emergency and the National Emergency Concerning the Novel Coronavirus Disease 2019 Pandemic ... Notice 2023-37 also clarifies whether certain items and services are treated as preventive care under section 223(c)(2)(C). S" Tags: COVID-19 • Cafeteria Plans • HSAs • Health Plan Information for Employees |
IRS Clarifies Prior Guidance on COVID-19 Testing and Treatment for HDHPs
Sequoia [Guidance Overview] Aug. 10, 2023 "After 2024, covering COVID-19 testing and treatment under an HDHP without participant cost-sharing, could impact a participant's Health Savings Account (HSA) eligibility. Notice 2023-37 also provides that COVID-19 testing will not be considered preventative care for purposes of HSA eligibility as of the Notice's publication date (June 23, 2023)." Tags: COVID-19 • HSAs • Health Plan Design |
IRS Issues Guidance on Expenses Related to COVID-19 and Preventive Care
Miller Johnson [Guidance Overview] July 28, 2023 "[F]or plan years ending after December 31, 2024, a high-deductible health plan will no longer be permitted to provide coverage for COVID-19 testing and treatment under the HDHP before the minimum HDHP deductible is met without jeopardizing a participant's HSA eligibility.... Notice 2023-37 ... clarified that the preventive care safe harbor does not include screening (i.e., testing) for COVID-19, effective as of June 23, 2023 ... [T]his clarification will not be relevant for HDHPs/HSAs until the first plan year ending after December 31, 2024." Tags: COVID-19 • Health Plan Administration |
COVID Testing and Treatment Are No Longer 'Preventive' Starting in 2025
HUB International [Guidance Overview] July 13, 2023 "IRS Notice 2023-37 [provides] that COVID testing and treatment are not preventive care. This means they can only be provided under a high deductible health plan ('HDHP') on a first dollar basis by plans which plan years end no later than December 31, 2024. HDHPs that continue to cover these services on a first dollar basis will cause their participants to be ineligible to contribute to health savings accounts (HSAs)." Tags: COVID-19 • Health Plan Design |
IRS Issues Guidance on COVID-19 Relief for HSA-Qualifying HDHPs
Willis Towers Watson [Guidance Overview] July 7, 2023 "Employer plan sponsors of HSA-qualifying HDHPs that currently cover COVID-19 testing and/or treatment prior to the satisfaction of the minimum annual HDHP deductible should amend the terms of the plan to no longer do so for plan years ending after December 31, 2024." Tags: COVID-19 • HSAs • Health Plan Design |
Determining COBRA Election and Payment Deadlines at the End of the COVID-19 Outbreak Period (PDF)
Thomson Reuters / EBIA [Guidance Overview] July 6, 2023 "If a participant experiences a qualifying event and is provided a COBRA election notice on or before July 10, 2023, the individual's 60-day period to elect COBRA begins to run on July 10, 2023 (making the deadline September 8, 2023).... Although not expressly addressed, it appears that if a qualifying event occurs on or before July 10, 2023, and the COBRA election notice is provided after that date, the COBRA election deadline would be measured from the provision of the notice." |
Post-Pandemic Realities: The Retirement Outlook of the Multigenerational Workforce (PDF)
Transamerica Center for Retirement Studies July 6, 2023 "Today's workers are navigating the extended hangover of the pandemic as well as new disruptions that pose a threat to their lifestyles and livelihoods. Many workers are confronting short-term employment and financial challenges that have implications for their ability to save and invest for their future retirement. A concerted effort is needed among policymakers, employers, and workers themselves to put them back on the road towards a financially secure retirement." Tags: COVID-19 • Retirement Plan Design |
IRS Issues Guidance on HDHP Relief for COVID-19 Services and Preventive Care
Groom Law Group [Guidance Overview] June 28, 2023 "[C]alendar year HDHPs must subject COVID-19 testing and treatment to the deductible beginning with the 2025 plan year. This gives HDHPs more than a year to transition to applying the deductible to these services. However, non-calendar year HDHPs will have less time since the relief will only apply until the end of the 2023 plan year. This is because a 2024 non-calendar year plan year will end after December 31, 2024." Tags: COVID-19 • Health Plan Design |
COVID-19 Health Plan Relief Winds Down
Mercer [Guidance Overview] June 28, 2023 14 pages. "This updated slide deck describes agency guidance on which COVID-19 coverage mandates expired once the public health emergency ended on May 11, and how to calculate key plan and participant deadlines before and after the outbreak period ends on July 10. The slides also describe employer actions that the agencies encourage but do not require, such as steps to lessen the impact of Medicaid redeterminations on employees and their families." Tags: COVID-19 • Health Plan Design |
For HDHPs, IRS Confirms Pre-Deductible COVID-19 Testing Coverage Will End Next Year
Proskauer [Guidance Overview] June 28, 2023 "The IRS's recent guidance on COVID-19 testing and treatment marks another (time-limited) eligible expense that plan sponsors will need to track as they monitor the scope of permissible expenses that can be covered under an HDHP before a participant satisfies the IRS minimum deductible." Tags: COVID-19 • Health Plan Design |
Special Rule Allowing Reduced Cost COVID-19 Testing and Treatment for HSA Plans Sunsets Next Year; Sunset Does Not Apply to COVID-19 Vaccines
Lockton [Guidance Overview] June 27, 2023 "For calendar year plans, this means that reduced-cost COVID-19 testing and treatment can be covered by an HDHP through Dec. 31, 2024. For non-calendar year plans, the relief applies through the plan year that ends in 2024." Tags: COVID-19 • Health Plan Design |
COVID-19 Coverage Without a Deductible Ends Next Year
Journal of Accountancy [Guidance Overview] June 26, 2023 "[Notice 2023-37] puts a deadline on the relief described in Notice 2020-15, issued in March 2020, by saying it applies only to plan years ending on or before Dec. 31, 2024." Tags: COVID-19 • Health Plan Administration • Health Plan Design |
Text of IRS Notice 2023-37: Expenses Related to COVID-19 and for Preventive Care, for Purposes of High Deductible Health Plans (PDF)
Internal Revenue Service [IRS] [Official Guidance] June 23, 2023 "[T]his notice modifies prior guidance regarding benefits relating to testing for and treatment of COVID-19 that can be provided by a health plan that otherwise satisfies the requirements to be a high deductible health plan (HDHP) ... Specifically, this notice provides that the relief described in Notice 2020-15 ... applies only with respect to plan years ending on or before December 31, 2024. "This notice also clarifies ... that the preventive care safe harbor ... does not include screening (i.e., testing) for COVID-19, effective as of the date of publication of this notice [June 23, 2023]. This notice also provides that items and services recommended with an 'A' or 'B' rating by the United States Preventive Services Task Force (USPSTF) on or after March 23, 2010, are treated as preventive care for purposes of section 223(c)(2)(C), regardless of whether these items and services must be covered, without cost sharing, under Public Health Service Act section 2713." Tags: COVID-19 • Health Plan Design |
California State Grant Program for COVID-19 Supplemental Paid Sick Leave
Jackson Lewis [Guidance Overview] June 16, 2023 "Eligible businesses may use the funds to reimburse for [supplemental paid sick leave (SPSL)] provided between January 1, 2022, and December 31, 2022. Businesses will be required to provide proof of employee payroll records that verify all SPSL provided by the business was pursuant to the state requirements" Tags: COVID-19 • FMLA and Other Leave • Local Regulation |
Colorado Amends Paid Sick Leave Law; Public Health Emergency Leave for COVID-19 Ends this Week
Seyfarth Shaw LLP [Guidance Overview] June 8, 2023 "In addition to the HFWA's original covered absences, once effective, the amended list of covered reasons for use of paid sick leave will include absences related to bereavement leave and certain closures or evacuations due to inclement weather, loss of power, or other unexpected events. The SB 23-017 amendments go into effect on August 7, 2023." Tags: COVID-19 • FMLA and Other Leave • SECURE 2.0 |
Massachusetts Division of Insurance Provides Special Enrollment Period for Loss of COBRA Coverage
The Wagner Law Group [Guidance Overview] June 6, 2023 "In response to the anticipated ending of the outbreak period on July 10, 2023, the Massachusetts Division of Insurance, on April 10, 2023, issued Special Bulletin 2023-09 to ... commercial health insurers, to address the implications of the ending of the National Emergency with respect to COBRA.... This Bulletin does not apply to self-insured group health plans, and it is still too early to determine the extent to which regulators in other jurisdictions will take similar action." Tags: COBRA • COVID-19 • Local Regulation |
The Impact of the (Official) End of the COVID-19 National Emergency
Bond, Schoeneck & King [Guidance Overview] June 1, 2023 "Prior to July 10, 2023, plan sponsors should begin to review and revise their health plan design and related documents with their plan administrators and legal counsel. To the extent that plan documents and participant communications were modified to reflect the temporary National Emergency deadlines, plan sponsors should evaluate whether the documents need to be revised to reflect the end of the National Emergency." Tags: COVID-19 • Health Plan Administration |