On October 4, 2021, the Department of Health and Human Services, Department of Labor and Treasury jointly issued FAQs relating to COVID-19 vaccine incentives and surcharges. Under the guidance, employers may provide incentives such as premium discounts or surcharges through group health plans to incentivize COVID-19 vaccines, provided the incentive complies with the activity-only
Understanding Employee Benefits and key developments in the employee benefits field and items of interest to our clients. MORE
Health Plan
IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA
On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the American Rescue Plan Act of 2021 (ARPA). For more information about the ARPA and COBRA subsidies, see Stinson’s previous blog: American Rescue Plan Act Contains…
DOL’s ARPA COBRA Subsidy Notices and FAQs: Stay Tuned for More
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law. Under ARPA, certain employees and their dependents who lost group health coverage during the COVID-19 pandemic due to the employee’s involuntary termination (other than for gross misconduct) or reduction of hours are allowed to temporarily receive fully-subsidized COBRA…
AMERICAN RESCUE PLAN ACT CONTAINS MANY EMPLOYEE BENEFITS RELATED PROVISIONS
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the “ARPA”) into law. Many of the provisions in this sweeping legislation bring changes to the employee benefits world of which employers should take note and which are summarized below.
Subsidized COBRA
The ARPA contains several new rules which impact COBRA…
IRS Guidance on Coronavirus Relief for FSAs, DCAPs, and Cafeteria Plans: Almost Anything Goes
On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (“FSAs”), and dependent care assistance programs (“DCAPs”) that were included in the Consolidated Appropriations Act (“CAA”), enacted on December 27, 2020. The Notice also adds temporary opportunities to make changes in health plan coverage under…
Annual Limits on Qualified Plans for 2021
On October 26, 2020, the Internal Revenue Service (IRS) released Notice 2020-79, which sets forth the 2021 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the dollar limitation for employee salary reductions for contributions to health flexible spending arrangements in Revenue Procedure 2020-45. The…
IRS Issues Coronavirus Relief for High-Deductible Health Plans
On March 11, the IRS issued Notice 2020-15. The new guidance permits high-deductible health plans (HDHPs) to pay for 2019 Novel Coronavirus (COVID-19) testing and treatment without a deductible (or with a deductible below the minimum annual deductible otherwise required), and without jeopardizing the plan’s status as an HDHP. This is significant guidance for…
Annual Limits on Qualified Plans for 2020
On November 6, 2019, the Internal Revenue Service (IRS) released Notice 2019-59, which sets forth the 2020 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments earlier this year…
FINAL HRA REGULATIONS CREATE NEW HEALTH COVERAGE OPTIONS FOR EMPLOYERS AND EMPLOYEES
On June 13, 2019 the Department of Health and Human Services, Department of Labor and Department of the Treasury released final regulations that create new healthcare coverage options for employers and employees. https://www.federalregister.gov/documents/2019/06/20/2019-12571/health-reimbursement-arrangements-and-other-account-based-group-health-plans
The new coverage options come in the form of two new types of health reimbursement arrangements (“HRAs”), one which allows employers to…
Are Your Business Associate Agreements In Place?
HHS Announces Significant Settlement Agreements for Noncompliance
On December 4 and December 11, 2018, the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) issued press releases announcing two settlements with health care providers for violation of the Health Insurance Portability and Accountability Act’s (HIPAA) privacy and security rules. Specifically, the…