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[Guidance Overview]
DC Paid Family Leave Tax is Here
"The first collection of paid family leave tax began on July 1st with contributions based on gross or total wages paid to 'covered employees' during the period April 1, 2019-June 30, 2019 ... [T]here are no exemptions for employers providing their own paid leave benefits."
WithumSmith+Brown, PC
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[Guidance Overview]
Digging Into the New HRA Regs: ERISA Implications
"In order to qualify for the safe harbor [exemption from ERISA] for individual insurance coverage, all of the following conditions must be satisfied: [1] The purchase of any individual health insurance coverage is completely voluntary for employees.... [2] The employer, employee organization, or other plan sponsor does not select or endorse any particular issuer or insurance coverage.... [3] Reimbursement for non-group health insurance premiums is limited solely to individual health insurance coverage ... [4] The employer, employee organization, or other plan sponsor receives no consideration in the form of cash or otherwise in connection with the employee's selection or renewal of any individual health insurance coverage.... [5] Each plan participant is notified annually that the individual health insurance coverage is not subject to ERISA."
Proskauer
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What Do the Latest HRA Rules Mean for Employer Healthcare Offerings?
"Employers should consider whether the following applies: [1] I need to provide coverage to a population that may not be eligible for our employer sponsored group health plan. [2] I'd like to offer coverage to new hires after a designated effective date. [3] I'd like a new way to meet our financial objectives. [4] I have a Gig population. [5] I have a growing contingent workforce and am looking for ways to attract and retain them. If you checked any of [those boxes], your organization may want to explore the new HRA options[.]"
Alight Solutions
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Third Circuit Upholds Nationwide Injunction Blocking ACA Contraceptives Final Rules
"For the time being, the Third Circuit's decision puts a hold on the expanded exemptions under the Trump Administration's November 2018 final regulations, until the states' APA-based challenge can be heard on the merits. The Third Circuit stopped short of vacating the regulations altogether -- though that was the ultimate remedy sought by the states. Entities that could have used the final regulations' expanded exemptions will not be able to do so." [Pennsylvania v. President of U.S., Nos. 17-3752, 18- 1253, 19-1129, 19-1189 (3d Cir. Jul. 12, 2019)]
Thomson Reuters Practical Law
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A Deep Dive Into Student Loan Repayment Assistance Benefits
"Four percent of responding organizations already offer some sort of student loan repayment assistance benefit.... Large employers (9.3%) are much more likely to offer loan repayment assistance than small (1.7%) and midsized (3.7%) organizations.... [P]otential barriers and challenges to implementing a student loan repayment program include cost (48.9%), uncertainty/complexity of implementation (31.4%), and potential resentment among workers who have already paid off loans (29.8%) or have ineligible loan debt (25.0%)."
International Foundation of Employee Benefit Plans [IFEBP]
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[Opinion]
Prediction: Congress Won't Whack the Cadillac
"In this installment of Congressional drama the supermajority will ... [say] that they can't kill the tax without offsetting revenues. They will again claim to be good stewards of our tax dollars and voice how much they dislike the tax. But when the dust has settled the Cadillac Tax will live."
InsureBlog
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Selected Discussions on the BenefitsLink Message Boards
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Married Employee Ages Out of Parent's Health Care Plan
We have an employee who is married and was covered by his parent's employer's health care plan. Coverage ended on 6/30/19. He wanted to use his special enrollment period to enroll not only himself but also his spouse (who has no qualifying loss of coverage). I told the employee he couldn't enroll his spouse, at this time, but I'm getting some pushback and want to make sure I'm not mistaken.
BenefitsLink Message Boards
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Most Popular Items in the Previous Issue
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David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager
BenefitsLink Health & Welfare Plans Newsletter, ISSN no. 1536-9595. Copyright 2019 BenefitsLink.com, Inc. All materials contained in this newsletter are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of BenefitsLink.com, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.
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