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[Guidance Overview]
IRS Letter 1865C: Correcting Your ACA Reporting Forms
"[If] the IRS receives an ACA reporting document that it cannot process, it will send a Form 1865C. This could happen for a variety of reasons, for example: A typo in your company's name or EIN; A misprint on the form where information does not appear in the proper box; Even the font being too small. Unfortunately, IRS Letter 1865Cdoes not do a great job of describing what the issue is."
HUB International
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[Guidance Overview]
Pittsburgh Paid Sick Leave: Implementation Guidelines and Effective Date
"An employer subject to the law includes any ... entity situated or doing business in the City, who employs one or more persons for a salary, wage, commission or other compensation.... Full-time and part-time individuals who work for a covered employer within the geographic boundaries of the City of Pittsburgh are covered employees. An employee who works for an employer located outside of the geographic boundaries of the City of Pittsburgh but performs work within the City boundaries is considered a covered employee once he/she performs at least 35 hours of work in a calendar year within the City boundaries."
CBIZ
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[Guidance Overview]
Seattle Mandates Commuter Benefits
"Beginning January 1, 2020, Seattle employers with twenty or more employees worldwide must provide transit benefits to their Seattle employees.... An eligible employee is one who work[ed] an average of ten hours or more per week in Seattle in the previous calendar month."
CBIZ
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CMS's Hospital Price Transparency Final Rule and Related Legal Challenge
"Like the drug price disclosure rule, this hospital price transparency rule has sparked debate and drawn a legal challenge by entities ... affected by the rule.... [This article] provides an overview of the CMS hospital price transparency final rule, the bases of the legal challenge against it, and how the legal challenge may be relevant to other legislative healthcare price transparency proposals that Members of Congress may continue to consider." [CRS LSB10392]
Congressional Research Service [CRS]
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Loopholes Limit New California Law to Guard Against Lofty Air Ambulance Bills
"[T]he new air ambulance law is like laws in California and other states that protect consumers from surprise medical bills: They don't apply to residents in federally regulated [self-funded] health plans. Those plans cover about two-thirds of people who get insurance through their jobs nationwide.... [W]hen other states have tried to prohibit air ambulance balance billing, the companies have often successfully challenged those laws on the grounds that the federal Airline Deregulation Act of 1978 prohibits state rate setting[.]"
Kaiser Health News
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'Toys R Us' Bill Could Soon Mandate Severance Pay for Laid-Off Employees in New Jersey
"New Jersey state lawmakers approved a bill Monday that would compel employers to give more notice and pay severance to laid-off workers ... The bill, which has been called the 'Toys R Us bill' for workers of the retail chain that filed for bankruptcy in 2017, requires larger employers to pay workers one week of severance for each year of service. It also gives employees 90 days' notice, rather than just 60 days, in the event of a mass layoff."
The Washington Post; subscription may be required
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Best Practices for HSA Investments and Menu Design (PDF)
"It may be advantageous to include more funds in an HSA menu than a 401(k) menu due to the wider range of use cases for HSAs, among other factors.... Menus should include a mix of asset classes that may contribute to the long-term upside potential of a portfolio without introducing excessive risk.... The product mix should complement selected asset classes through active or passive options where appropriate and provide single-fund portfolio options such as allocation and target-date funds."
Devenir
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[Opinion]
American Academy of Actuaries Comments to CMS on Wellness Program Demo Project in the Individual Market (PDF)
"Evidence finds that many wellness programs do not achieve cost savings or improve health outcomes ... Wellness programs should not be used to exclude less healthy individuals ... Clarification is needed regarding actuarial value requirements and benchmark premium calculations ... Wellness program rewards or penalties could increase advanced premium tax credits (APTCs) ... Wellness program rewards and penalties could affect subsidized and unsubsidized enrollees differently, depending on the program's design."
American Academy of Actuaries
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[Opinion]
MMS Analytics, Inc. Comment Letter to CMS on Transparency in Coverage
"If we have truly done away with the fiction that network-negotiated rates for care are confidential and proprietary, and this information is being made available in machine-readable format for public use, then this information must be shown on all requests for price made by consumers. Without it, even the most motivated consumer cannot exercise full control over their purchasing power."
MMS Analytics, Inc.
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Benefits in General
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[Official Guidance]
Text of DOL Final Regs: Federal Civil Penalties Inflation Adjustment Act -- Annual Adjustments for 2020
41 pages. "The cost-of-living adjustment multiplier for 2020, based on the Consumer Price Index (CPI-U) for the month of October 2019, not seasonally adjusted, is 1.01764. In order to compute the 2020 annual adjustment, the Department multiplied the most recent penalty amount for each applicable penalty by the multiplier, 1.01764, and rounded to the nearest dollar."
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]
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BenefitsLink Health & Welfare Plans Newsletter, ISSN no. 1536-9595. Copyright 2020 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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