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Health & Welfare Plans Newsletter

May 26, 2021

4 New Job Opportunities


[Guidance Overview]

IRS Clarifies Taxation of Dependent Care Benefits Due to Extended Grace Periods or Expanded Carryovers

"[Notice 2021-26] states that amounts which are available under the extended grace period or expanded carryover options will be excludable from the employees' gross income if: [1] The amounts would have been excluded from employees' income had they been used during the original taxable year ending in 2020 or 2021; and [2] If the available amounts due to the extended grace period or expanded carryover options are actually used during the following taxable year."  MORE >>

Fraser Trebilcock

[Guidance Overview]

Exceptional Usefulness and Quality icon IRS Uncoils COBRA Subsidy Guidance

"The IRS previously published FAQ guidance in 2009 related to a similar 65% COBRA premium subsidy under the American Recovery and Reinvestment Act (ARRA).... While [Notice 2021-31] largely tracks the 2009 guidance, there are certain notable exceptions."  MORE >>

Groom Law Group

[Guidance Overview]

IRS Bites Into COBRA Subsidy Questions Under ARPA

"IRS Notice 2021-31 provides helpful clarifications about the eligibility of COBRA QBs for the COBRA subsidies, the subsidy period, the calculation of the Medicare tax credit, and more. This client alert highlights some of the key points in this new guidance."  MORE >>

Miller Johnson

[Guidance Overview]

IRS Answers ARPA COBRA Subsidy Questions

"If an AEI's COBRA qualifying event was before April 1, 2021, ... the plan sponsor must make subsidized COBRA available starting as of April 1, 2021, [but] the IRS has now told us that an AEI has the option to waive subsidized COBRA for the period between April 1, 2021 and his or her actual election.... [T]he DOL model Extended Election Notice does not address or include any election mechanism for an AEI's option to waive COBRA coverage for the period between April 1, 2021 and an AEI's actual election."  MORE >>


HHS HIPAA Security Rule Settlement Imposes Extensive Independent Monitoring Requirements

"From the certification and credentialing requirements for an independent monitor to the restrictions imposed on this CE for terminating its monitor, the independent monitoring requirements could make carrying out this [corrective action plan] more challenging than it otherwise would be."  MORE >>

Thomson Reuters Practical Law

Google Strikes Deal with Hospital Chain to Develop Healthcare Algorithms

"[HCA Healthcare, Inc.], which operates [hospitals] across about 2,000 locations in 21 states, would consolidate and store with Google data from digital health records and internet-connected medical devices under the multiyear agreement. Google and HCA engineers will work to develop algorithms to help improve operating efficiency, monitor patients and guide doctors' decisions, according to the companies."  MORE >>

The Wall Street Journal; subscription may be required

OIG Report: Anthem Coding Errors Resulted in CMS Overpayments of $3.47 Million

"For 123 of the 203 enrollee-years, the diagnosis codes that Anthem submitted to CMS were not supported in the medical records and resulted in $354,016 of net overpayments for the 203 enrollee-years.... On the basis of our sample results, we estimated that Anthem received at least $3.47 million of net overpayments for these high-risk diagnosis codes in 2015 and 2016."  MORE >>

Office of Inspector General [OIG], U.S. Department of Health and Human Services [HHS]

Employee Benefits Jobs

View job as Associate Attorney (Employee Benefits and Executive Compensation)
for Roberts & Holland LLP Associate Attorney (Employee Benefits and Executive Compensation)

Roberts & Holland LLP

New York NY

View job as Associate Attorney (Employee Benefits and Executive Compensation)
for Roberts & Holland LLP

View job as Manager, Customer Relationships
for National Automobile Dealers Association Manager, Customer Relationships

National Automobile Dealers Association

Mc Lean VA

View job as Plan Document Specialist
for Vestwell Plan Document Specialist


Telecommute / New York NY

View job as Senior Document Compliance Consultant
for TIAA Financial Services Senior Document Compliance Consultant

TIAA Financial Services

Telecommute / Charlotte NC

Selected New Discussions

Designing a 'Flexible Benefits Plan' in the Form of Choices Among Various Benefit Plans

"As part of an employer's overall benefit program, is it allowable to allocate X dollars per employee of employer contributions, which the employee can then use to choose among various options? For example, if an employer allocates $5,000 per employee, the employee then can choose to have the a portion directed into the HRA, the Section 127 plan, the Health Insurance, or the Cafeteria plan. The employee would NOT be able to receive any of this in cash."

BenefitsLink Message Boards

Press Releases

Transamerica Expands Employee Benefits Offerings with New Group Life, Disability Solutions


Ascensus Appoints New Regional Vice President


Chambers USA 2021 Ranks Groom as Top Tier Employee Benefits & Executive Compensation Firm and Awards Its ERISA Litigation Practice

Groom Law Group

ARA Expands Member Advocacy & Engagement Focus With New Position

American Retirement Association [ARA]

Webcasts and Conferences
(Health & Welfare Plans)

ARPA Benefits Compliance Updates and FAQ, Part 5


NFP Corp.

Saving for Health Care in Retirement: How HSAs and 401(k)s Fit Together

June 9, 2021 WEBCAST

EBRI [Employee Benefit Research Institute]

Go All the Way with HSA

June 15, 2021 WEBCAST

ABD Insurance & Financial Services

California Leaves of Absence Update and Tips for Preventing Leave-Related Employee Benefit Chaos

June 17, 2021 WEBCAST


Last Issue's Most Popular Items

IRS Weighs In on ARPA COBRA Subsidies, Including Some Surprises


Text of Draft 2021 IRS Form 1095-C: Employer-Provided Health Insurance Offer and Coverage (PDF)

Internal Revenue Service [IRS]

ARPA Premium Subsidy: Long-Awaited Details Finally Arrive

Verrill Dana LLP

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BenefitsLink Retirement Plans Newsletter, ISSN no. 1536-9587.

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