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Health & Welfare Plans Newsletter

July 22, 2022

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[Guidance Overview]

ACA Reporting: Asking (Repeatedly) for Social Security Numbers

"When the SSN is missing, or if the employer has been notified that the SSN is incorrect, it must engage in 'reasonable efforts' to obtain the missing or correct SSN. 'Reasonable efforts' means that employers must complete a three-step process: [1] Initial solicitation ... [2] First annual solicitation ... [3] Second annual solicitation ... Documentation of the solicitation process is important."  MORE >>

HUB International

[Guidance Overview]

ICHRA Pitfalls for Employers to Avoid

"[1] Failing to understand the authorized classes ... [2] Failing to understand minimum class size rules.... [3] Failing to understand rating areas.... [4] Failing to comply with substantiation requirements.... [5] Failing to understand COBRA applicability."  MORE >>

HUB International

[Guidance Overview]

Alert (High Risk Issue) icon 2022 Changes to Michigan's Paid Medical Leave: Back to the Future

"Employers may want to examine their current leave policies for Michigan employees and assess any necessary modifications needed to comply with the expanded paid sick leave (and other) provisions of the original legislation. Here is a recap of the most notable provisions in the original law[.]"  MORE >>

Ogletree Deakins

[Guidance Overview]

Alert (High Risk Issue) icon Michigan Court Reinstitutes More Generous Paid Sick Time Law, Effective Immediately

"Unless the Michigan Court of Appeals or Supreme Court issues a stay pending an appeal, ... [all] Michigan employees are now eligible for paid sick leave, including previously exempted part-time, executive, administrative, professional, and outside sales employees. Employers must provide 1 hour of sick leave for every 30 hours worked (instead of the prior 1:35 ratio). Employers with less than 10 workers may cap paid time off at 40 hours annually; all others must provide employees up to 72 hours of paid time off annually."  MORE >>

LaborSphere, a blog by Drinker Biddle

Issues for Employers After the Dobbs Decision

"[1] How does the Dobbs decision affect our ability to reimburse travel for abortion services? ... [2] How does Dobbs impact abortion medications? ... [3] How can we support employee mental health? ... [4] How does Dobbs affect family-building benefits? ... [5] Does Dobbs impact contraception? ... [6] How could Dobbs impact overall medical costs? ... [7] Could Dobbs impact diversity, equity and inclusion initiatives as well as childcare benefits?"  MORE >>

Willis Towers Watson

Employers Offering Abortion Expense Coverage Seek Agency Guidance on ERISA Preemption, Other Federal Laws

"Two employer business groups are asking government agencies for guidance that would provide them protection against states seeking to block them from covering abortion services after the US Supreme Court’s ruling overturning Roe v. Wade.... The Business Group on Health earlier this month sought help from the secretaries of [HHS], Labor, and the Treasury.... The HR Policy Association also sent a letter to the three agencies asking for governmental guidance on issues related to the high court's decision in Dobbs[.]"  MORE >>

Bloomberg Law

Consumer Attitudes Toward Employer-Provided Health Coverage in 2022 (PDF)

"The majority of Americans with employer-provided coverage (67%) are satisfied with their current coverage and a similar number (64%) believe the quality of their plan is high.... [A] majority report employer-provided coverage is effective in meeting the overall health care (66%) and the mental health care (56%) needs of the children enrolled in and covered by those plans."  MORE >>

Locust Street Group, for AHIP

CBO Report: Effects of Proposal to Extend Premium Tax Credits and Proposed Regs on Affordability of Coverage for Family Members (PDF)

"Under the May 2022 baseline, CBO and JCT estimate that if the [premium tax credit] enhancements became permanent, federal deficits would increase by $247.9 billion over the 2023-2032 period -- a result of increases in direct spending of $181.4 billion and decreases in revenues of $66.5 billion over the period.... Under the May 2022 baseline, CBO and JCT estimate that, if the proposed regulation [as to affordability of family coverage] is made final, the number of people enrolled in nongroup coverage would increase, on average, by 900,000 in each year over the 2023-2032 period."  MORE >>

Congressional Budget Office [CBO]

Employee Benefits Jobs

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Retirement Solutions Specialists, LLC

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Press Releases

LeafHouse is Recognized by DALBAR for Providing Exceptional Investment Management Services to Retirement Plans

LeafHouse

Last Issue's Most Popular Items

Preparing for the End of COVID-19 Emergency Periods: To-Dos for Plan Sponsors and Administrators

Morgan Lewis

HHS OIG Issues Special Fraud Alert on Arrangements with Telemedicine Companies

Foley & Lardner LLP

Michigan Court Voids Current Paid Medical Leave Law, Reinstating Original Versions from 2018

Miller Johnson

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

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