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[Guidance Overview]
"[P]lans have a relatively short amount of time to build complex systems to support information requests.... The rule allows employers with fully-insured group coverage to transfer full liability to their health insurance issuer as part of their coverage contract. However, because the underlying law doesn't allow it, there is no such liability shield for self-funded or level-funded plans.... [T]he measure does not require the disclosure of any provider quality information because of regulatory process limitation."
MZQ Consulting, LLC
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[Guidance Overview]
"[T]he 2021 open enrollment period began in most states on November 1, 2020 and extends through December 15, 2020. This post discusses additional data and resources from the [CMS] in light of the open enrollment period and a new proposed methodology for the Basic Health Program (BHP) for 2022."
Katie Keith, in Health Affairs Blog
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[Guidance Overview]
38 pages; rev. Nov. 2, 2020. "To alleviate some of the economic strain on employees unable to work due to COVID-19, some state and local authorities have implemented new paid leave requirements. Other jurisdictions modified existing leave laws or benefit programs to accommodate employees' needs during the pandemic. This GRIST provides brief summaries of the new state and local paid leave benefits, as well as guidance addressing how current paid leave benefits apply during the COVID-19 pandemic."
Mercer
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[Guidance Overview]
"On September 30, 2020, the New York State Department of Financial Services (DFS) and Department of Health (DOH) promulgated regulations requiring health insurers operating in the state to develop and implement a mental health and substance use disorder (MH/SUD) parity compliance program. Health plans are required to have these parity compliance programs in place by December 29, 2020, and must annually attest to the DFS or DOH that such programs are in place."
Manatt, Phelps & Phillips, LLP
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[Guidance Overview]
"[T]he guidance does not clearly address key questions left open by the [New York Sick Leave Law (NYSLL)], including: [1] If an employer provides a lump sum of paid sick leave at the beginning of each year (also known as front-loading), whether the employer must still allow employees to carry over accrued, unused leave at the end of the year. [2] In determining the amount of sick leave the employer is required to provide, whether to count only employees within New York or employees nationwide.... [3] Whether employers can require reasonable documentation to support an employee's request to use New York Sick Leave."
Pepper Hamilton LLP
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"(DOL) recently issued new forms you can use to meet the notice and certification requirements of the Family and Medical Leave Act (FMLA). Here are six good reasons to use the new forms.... [1] Easier for employees to understand ... [2] Employee confidence in FMLA processes bolstered ... [3] Safer to use than forms you create yourself ... [4] Faster than creating your own ... [5] 'Touchless' way of meeting FMLA requirements in COVID-19 era ... [6] Motivating healthcare providers to be more accurate, complete."
HR Daily Advisor
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"SB 1123 expanded the Paid Family Leave program to include time off for employees to attend to a 'qualifying exigency' related to an individual's spouse, registered domestic partner, parent, or child who is an active duty member of the United States Armed Forces. Although SB 1123 was passed in 2018, the changes do not go into effect until January 2021."
Jackson Lewis
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