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What Employers Should Know About Individual Coverage HRAs
"ICHRAs are an alternative to traditional group health plan coverage ... Employers can offer different ICHRA coverage to different classes of employees ... There is no dollar limit on an employer's annual contribution to an employee's ICHRA ... An ICHRA can satisfy the Employer Mandate under the ACA ... ICHRA must provide notice to employees describing the ICHRA and the interaction of the ICHRA and the ACA premium tax credit ... ICHRAs are not subject to ERISA if certain requirements are met."
Thompson Coburn
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Plans Need Not Count Drug Manufacturer Coupons Toward the ACA's Cost-Sharing Annual Limits
"The Departments acknowledged that interpreting the final rule to require drug manufacturer coupons to count toward the ACA's cost-sharing limits could conflict with prior IRS guidance on high deductible health plans (HDHPs) and health savings accounts (HSAs).... As a result, the final rule's provision on counting drug manufacturers' coupons could make it difficult for plans and insurers to comply with both the final rule and the prior HDHP rules."
Thomson Reuters Practical Law
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How a Union's Plan Could Foreshadow Changes in Maternity Care Nationwide
"An SEIU health fund is expected to request that area hospital systems provide information on rates of maternal harm and apply to a newly created program promising higher-quality, higher-value care ... More employers could be expected to implement both episodic payment models for pregnancy and non-payment for elective, pre-term C-sections. This change will shift services from higher-reimbursing C-sections to lower-paying normal deliveries."
Healthcare Financial Management Association [HFMA]
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Relief Coming for Parking Expenses? Not-for-Profits Hold Out Hope
"Until further guidance comes, the only relief available to not-for-profits is a temporary respite from potential penalties for failure to timely deposit estimated taxes.... The calculation of total parking expenses, not the UBTI inclusion itself, is often the most burdensome task. The IRS is considering various methods to simplify this calculation."
CBIZ
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New York Boosts Job, Leave Rights for Domestic Violence Victims
"Employers will have to provide reasonable time off to victims of domestic violence ... Employers can require use of paid leave first ... Domestic violence victims who have no paid leave available may take unpaid leave. Health insurance must continue during the leave."
Mercer
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New York State to Require Reasonable Accommodation for Victims of Domestic Violence
"New York State employers will now be required to grant employees who are victims of domestic violence reasonable time off ... to: [1] seek medical attention for injuries caused by domestic violence; [2] obtain services from a domestic violence shelter, program, or rape crisis center or obtain psychological counseling; [3] participate in safety planning or to take other actions to increase safety from future incidents of domestic violence; and/or [4] obtain legal services, assist in the prosecution of the offense, or appear in court in relation to the incident of domestic violence."
Proskauer
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DOL Seeks to Improve Employers' FMLA Forms
"The proposed revisions aim to improve FMLA compliance and administration by making the forms easier to understand and use ... The DOL anticipates that the revisions will ultimately improve customer service and reduce the burden on the public."
Ballard Spahr LLP
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David Rhett Baker, J.D., Editor and Publisher
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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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