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Health & Welfare Plans Newsletter

November 2, 2021

5 New Job Opportunities 5 New Job Opportunities


[Official Guidance]

Text of CMS Memorandum to Issuers Offering Health Insurance Coverage in the Small Group Market: Temporary Policy on 2021 Premium Credits (PDF)

Nov. 1, 2021. "CMS is permitting small group market health insurance issuers, subject to the applicable state regulator's permission, the flexibility in non-merged market states to temporarily offer premium credits for 2021 coverage. CMS believes that small employers will benefit from this additional flexibility to maintain continuous comprehensive coverage for their employees while recovering from the financial instability caused by the COVID-19 [public health emergency]."  MORE >>

Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]

[Guidance Overview]

IRS Information Letter Addresses Employee Prescription Drug Rebates and HDHPs

"HDHP/HSA participants can use drug coupons and discounts, provided that the value of the coupon or discount does not count towards the HDHP minimum deductible. While insured HDHPs must cover certain benefits under applicable state laws, those benefits may not be covered without cost-sharing that is otherwise applicable to non-preventive services before the deductible is met."  MORE >>


[Guidance Overview]

Exceptional Usefulness and Quality icon New Health Plan Requirements for Employers in 2022: Consolidated Appropriations Act Checklist

"Removal of gag clauses ... Broker and consultant compensation disclosure ... Medical and drug cost reporting ... Mental health parity and addiction equity act (MHPAEA) comparative analysis ... Surprise billing ... Surprise air ambulance bills ... Reporting requirements regarding air ambulance services ... Modify identification cards ... No discrimination against certain providers ... Advanced explanation of benefits (EOB) ... Continuity of care ... Price comparison tool ... Provider directory and coverage information requests."  MORE >>

The Alliance

[Guidance Overview]

Tri-Agencies Issue FAQs Regarding COVID-19 Vaccine and Group Health Plan Premium Discounts

"Employers should calculate the incentive limit to ensure that the vaccine incentive, taken together with all other non-tobacco incentives, does not exceed the 30% incentive limit, particularly if the employer had previously considered the COVID-19 vaccine as a participatory wellness program.... [E]mployers should ensure that the ACA affordability standards are still being met assuming that participants do not earn the COVID-19 vaccine incentive."  MORE >>

Calfee, Halter & Griswold LLP

[Guidance Overview]

Agencies Clarify How Employers Can Charge COVID-19 Vaccine Premium Incentives

"Employers and group health plan sponsors considering implementing vaccine premium incentives should ensure that they comply with all of the criteria for activity-only health-contingent programs in the HIPAA wellness regulations and account for vaccine premiums in their ACA affordability calculations."  MORE >>

McDermott Will & Emery

[Guidance Overview]

Upcoming Deadline icon Alert (High Risk Issue) icon Self-Funded Employers May Need to Pay Washington State Mental Health Program Fee

"Washington State recently passed legislation requiring health insurance carriers and health plans to pay a quarterly assessment to assist medical providers with managing patients' mental health needs. Health insurance carriers will pay on behalf of fully insured plans, but self-funded plans may need to pay the fee themselves.... Employers subject to ERISA may argue that they are exempt from the fee due to ERISA preemption of state laws, but Washington state law specifically says that the fee applies to any plan that covers employees living in the state of Washington, including self-funded plans sponsored by employers located in other states. "  MORE >>


How Employers Can Help Ensure a Smooth Open Enrollment

"Holding meetings via webinar or video conference will allow for remote or dispersed workers to participate and stay involved.... Be sure that all communication is clear and concise with important dates and changes highlighted. Don't rely on only one channel.... Mailings should be sent to those on COBRA as well as anyone that may not have access to company communication."  MORE >>

Corporate Synergies

Democrats Drop Medicare Dental and Vision Coverage from Social Spending Bill But Voters Say It's Their Top Priority

"Across political parties, voters' top priority for the bill is adding dental and vision benefits to Medicare, which was cut from the White House's latest framework after intense pushback from dental groups and amid concerns about the price tag.... Among the 18 provisions listed in the poll, voters' second-highest priority is funding for home health care for seniors and people with disabilities, followed by Medicare drug price negotiation."  MORE >>

Morning Consult


Rulemaking for Health Care Affordability: Implementing the No Surprises Act

"As rulemaking finalizes, HHS can use three unique No Surprises Act provisions to build durable affordability standards through the mandated arbitration process ... HHS should also carefully monitor the IDR turnaround time and characteristics of arbitration requests to make sure payers and providers do not manipulate or inadvertently overwhelm the system ... The long-term risk to these 'compromise' solutions embedded in the No Surprises Act is that average people could pay more out of pocket in the form of premiums."  MORE >>

Ryan Koski-Vacirca and Arjun Venkatesh, in Health Affairs Blog

Benefits in General

GAO Report on Social Security and Medicare: Improving the Timeliness of Trust Fund Reports

"In 2019, GAO reported that the trustees issued their annual reports to Congress after the statutory deadline in 17 of the 25 years from 1995-2019 ... Treasury missed its April 1 deadlines for the 2020 and 2021 reports.... This report [1] describes Treasury's progress in addressing GAO's 2019 recommendations, and [2] offers potential actions ... that could help ensure timely completion of the Trustees reports." [GAO-21-105413, published Sep. 30, 2021, released Nov. 1, 2021]  MORE >>

U.S. Government Accountability Office [GAO]

Employee Benefits Jobs

View job as Participant Directed Retirement Plan Specialist
for T Bank, NA, a Tectonic Financial Company Participant Directed Retirement Plan Specialist

T Bank, NA, a Tectonic Financial Company


View job as Participant Directed Retirement Plan Specialist
for T Bank, NA, a Tectonic Financial Company

View job as Benefits Specialist
for Pension Benefit Guaranty Corporation [PBGC] Benefits Specialist

Pension Benefit Guaranty Corporation [PBGC]

Remote / Euclid OH

View job as Recordkeeper Specialist
for Benetic, Inc. Recordkeeper Specialist

Benetic, Inc.


View job as Retirement Plan Administrator (Entry Level)
for TriStar Pension Consulting Retirement Plan Administrator (Entry Level)

TriStar Pension Consulting

Remote / Oklahoma City OK

View job as Retirement Client Services Manager
for Newport Retirement Client Services Manager


Remote / Folsom CA / Chicago IL / Saint Petersburg FL / Lake Mary FL / La Crosse WI / Charlotte NC / Mobile AL / Overland Park KS / Dallas TX / West Des Moines IA / Los Angeles CA / Pittsburgh PA

Press Releases

OneAmerica Launches New Retirement Plan Offering More Flexibility and Streamlined Administration


Goldman Sachs Asset Management and Ascensus Offer a Retirement Plan Solution for Small and Mid-Sized Businesses


Webcasts and Conferences
(Health & Welfare Plans)

Health Policy Regulation for Employers


The Alliance

Vaccination Incentives and Employer-Sponsored Benefit Plans



Benefit Plans in the COVID-19 Era: 2021 Year-End Action Items and 2022 Considerations

November 9, 2021 WEBCAST

Western Pension & Benefits Council - Denver Chapter

Last Issue's Most Popular Items

How Employers Can 'Carve-Out' Group Health Plan Savings

Employee Benefits Report

Ninth Circuit Affirms Attorneys' Fee Award to ERISA Welfare Plan in Dispute Brought by Health Care Providers

Roberts Disability Law

Teladoc Ramping Up Focus on Virtual Primary Care with Plans to Take on Financial Risk


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

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