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HR Policy Association Comments to EEOC on Proposed Wellness Program Rule: 'EEOC Does Not Have the Statutory Authority'

"Although the proposed rule would restrict the ability of employers to administer gated health care plans, the EEOC does not have the statutory authority under the ADA's insurance safe harbor provision to impose such restrictions ... The EEOC's blanket rejection of a key 11th Circuit decision involving the ADA's 'safe harbor' (Seff v. Broward County) is inappropriate, and the agency should recognize that some wellness plans may fall within that provision."

HR Policy Association Comment Letter to HHS on Notice of Benefit and Payment Parameters for 2015 (PDF)

"While making payments in two installments is welcome, we strongly encourage [HHS] to allow self-insured employers to have the option, at their discretion, to pay the entire reinsurance fee in January of each year should they find it beneficial to do so.... After carefully reviewing the NPRM and consulting with our members, we wish to address four major items of concern: [1] Self-insured self-administered plans should be a contributing entity for the transitional reinsurance program; [2] The definition of third party administrators is unnecessarily complicated; [3] Self-insured group health plans should not be required to pay the costly treasury contribution amount; and [4] Excess collections should not be used to increase coinsurance rates."

American Benefits Council/HR Policy Association Comments on Interim Final Rules on Genetic Information in Health Insurance Coverage and Group Health Plans (PDF)

12 pages. "We are particularly concerned about the significant restrictions the Rules impose on employers' ability to effectively use HRAs and disease and case management programs to improve employee health."

HR Policy Urges Congress to Strengthen ERISA and Preserve Its Preemption Provisions

"HR Policy reiterated the importance of the national framework provided by ERISA during the COVID-19 pandemic. Due to this framework, employers were able to quickly implement crucial health care services, like telehealth, nationally. The comments urged the Committee to 'reject any attempts to weaken the federal restriction on state-by-state regulation of self-insured employers.' "

New Pension Law Makes Changes Aligned with HR Policy Retirement Security Recommendations (PDF)

2 pages. Excerpt: Facilitating Certain Defined Benefit Terminations. The HR Policy membership expressed significant interest in making DB to DC conversions easier. The PPA takes a small step in this direction by making it less expensive to terminate a part of a fully funded defined benefit plan when a company that is part of a controlled group is sold or otherwise divested, if certain requirements are met.

Large Employer Association Reacts to Senate Finance Health Care Reform Proposal (PDF)

Excerpt: From HR Policy's perspective, the proposal represents a significant improvement over the House and Senate HELP proposals and is a step in the right direction to achieving true reform, but it still falls short of the key consensus objectives identified in the HR Policy Association's Position Regarding the Reform of the U.S. Health Care System and significantly raises the cost of employer-provided health care. Several provisions are consistent with the Association's position, including[.]

HR Leaders Urge the President and Congress to Consider the Views of the Employer Community in Designing Comprehensive Health Care Reform (PDF)

4 pages. "Statement By Jeffrey C. McGuiness, President and CEO of the HR Policy Association, Representing the Views of Association Members on Reform of the U.S. Health Care System."

Association Health Plan Bills' Aim Is to Help Small Business Employees Obtain Health Benefits (PDF)

2 pages. Excerpt: Congress, with the backing of President Bush, is considering legislation intended to assist small employers in offering health insurance to their employees through pools referred to as association health plans (AHPs). The Small Business Health Fairness Act of 2005 (H.R. 525), introduced by Rep. Sam Johnson (R-TX), was reported out of the House passed the House on April 13, 2005. A companion measure (S. 406) was introduced in the Senate by Sen. Olympia Snowe (R-ME).

2018 ISS Policy Survey Queries Use of Pay Ratio

"ISS asks two questions about how the U.S. pay ratio will be used.... [1] [H]ow the data will be analyzed and whether it will be used to compare companies, to assess year-on-year changes at an individual company, or not used at all.... [2] [H]ow shareholders should use the pay ratio -- as a data point for evaluating compensation related votes, for evaluating director votes, to assist in engaging with companies, as a 'risk factor' in making investment, or not at all because it will not be meaningful to investors."

Policy Brief: Tax Laws Discourage Phased Retirement for Employers with Traditional Pensions (PDF)

2 pages. Excerpt: With people living longer, healthier lives, many boomers who approach retirement do not want to retire completely. Instead, they would like to reduce their work schedules and make up the income difference by receiving a reduced share of their retirement benefits, a process known as phased retirement. For employers with defined benefit plans, current tax rules prohibit this practice prior to the plan's normal retirement age.