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Health & Welfare Plans Newsletter

May 19, 2021

4 New Job Opportunities


[Guidance Overview]

Alert (High Risk Issue) icon Tri-Agency FAQs Tell Employers to Produce Robust and Well-Reasoned Mental Health Parity Analyses

"In recently issued FAQs, the Departments made it abundantly clear that general statements of compliance and conclusory references will not suffice in demonstrating parity. The Departments will be looking for detailed and well-reasoned explanations of the application of the nonquantitative treatment limitations (NQTLs) to mental health and substance use disorder (MH/SUD) benefits as compared to medical and surgical (MS) benefits in each of six benefit classifications."  MORE >>

Nixon Peabody LLP

[Guidance Overview]

Agencies Provide Guidance for Newly Required Mental Health Comparative Analysis

"For insured plans, this responsibility falls on the insurer. However, for self-insured plans, the employer is solely responsible and cannot expect third-party administrators to prepare the analysis.... [P]reparing an analysis that compares the application of NQTLs to MH/SUD benefits and to medical and surgical benefits is no simple matter.... Agency requests for the comparative analysis may be random or in response to a complaint alleging a parity violation."  MORE >>


[Guidance Overview]

Got COBRA Subsidy Questions? The IRS Has Answers

"Notice 2021-31 ... addresses a number of the key issues in a question and answer format.... The definition of involuntary termination of employment qualifying an individual for the subsidy is the same as was used in connection with a prior COBRA subsidy under the American Recovery and Reinvestment Act of 2009 ... This is a facts and circumstances test."  MORE >>

E is for ERISA

[Guidance Overview]

2022 ACA Cost-Sharing Caps and Other Changes Set; Employer Shared Responsibility Penalties Projected

"Part 2 of the Notice of Benefit and Payment Parameters for 2022 ... provides the adjustment factor used to update the ACA's cost-sharing limits (also called the out-of-pocket (OOP) maximums), employer shared-responsibility (ESR) assessments and the maximum employee contribution percentage for 'affordable' employer coverage.... Other items in the notice focus on implementation and enforcement of existing standards and increased transparency for prescription drug information in the individual and small-group insurance markets."  MORE >>


Estimating the Cost Impact of ARPA’s COBRA Subsidies

"[On] average, a COBRA participant costs 54% more than an active participant and, historically, only 10% of terminated employees elect COBRA (with cost being the primary deterrent). Since the subsidies provided by ARPA will allow employees who were or will be involuntarily terminated to continue coverage at no cost, it is reasonable for employers to be concerned."  MORE >>

NFP; free registration required to view full report

House HELP Committee Hearing on Paid Leave for Working Families: Examining Access, Options, and Impacts

Video of hearing held May 18, 2021, with testimony by [1] Vicki Shabo, Better Life Lab at New America; [2] Marcia St. Hilaire-Finn, Bright Start Early Care and Preschool; [3] Marianne McManus, IBM, on behalf of the American Benefits Council; and [4] Elizabeth Milito, National Federation of Independent Business.  MORE >>

Committee on Health, Education, Labor and Pensions, U.S. Senate

Strategies for Addressing Employees' Emotional Wellbeing and Mental Health

"Ensure your medical and pharmacy plan design and mental health vendor partners are the right fit for your employees, their dependents, and your organization, and that your provider network is sufficiently broad.... Employee education is important, but easy navigation of the mental health care system may ultimately be more dependent on good design.... Direct people to the right level of care.... Communicate appropriately."  MORE >>


Benefits in General

2021 Financial Life Benefits® Impact Report (PDF)

19 pages. "Even amid the pandemic, employees made progress toward their retirement with average 401(k) account balances increasing from $74,000 to $81,000 ... [R]etirement plans offering target-date funds [increased by] 17% and those offering sustainable investment options [grew] by 9% ... Employees are taking control of health care expenses, increasing their HSA balances by 17% and investing these savings to help cover future health care expenses."  MORE >>

Bank of America

Employee Benefits Jobs

View job as Plan Administrator
for Prime Pensions, Inc. Plan Administrator

Prime Pensions, Inc.

Florham Park NJ

View job as Plan Administrator
for Prime Pensions, Inc.

View job as Defined Benefits Specialist
for Corestaff Services Defined Benefits Specialist

Corestaff Services

Enfield CT

View job as Defined Benefit Plan Consultant
for Planned Retirement Consultants & Administrators, LLC Defined Benefit Plan Consultant

Planned Retirement Consultants & Administrators, LLC

Telecommute / Ridgewood NJ

View job as 401k & Defined Contribution Plan Consultant
for Planned Retirement Administrators & Consultants, LLC 401k & Defined Contribution Plan Consultant

Planned Retirement Administrators & Consultants, LLC

Telecommute / Ridgewood NJ

Last Issue's Most Popular Items

Text of IRS Notice 2021-31: Premium Assistance for COBRA Benefits (PDF)

Internal Revenue Service [IRS]

Price Transparency May Be Coming Sooner Than You Think

HUB International

IRS Releases 2022 Health Plan Limits


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