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Recent Insights

NO LATER THAN SEPTEMBER 15, 2021: Notice of Expiration to AEIs of ARPA COBRA Premium Assistance

Under provisions of the American Rescue Plan Act (“ARPA”), COBRA administrators are required to provide Assistance Eligible Individuals (“AEIs”) with written notice of the date on which their COBRA subsidy will end. The notice must be provided no earlier than 45 days before the expiration date and no later than 15 days before that date. […]

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HR Elements: Brainstorm Techniques to Elevate Team Creativity

READ TIME: 3 MINUTES “How should we fix this problem?” is a question that has been asked time and again in the boardroom, around the lunch table and likely on your last Zoom call at work. In this scenario, some may look to the most experienced person in the room or on the call to […]

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Guidance on ARPA COBRA Subsidy

Source: HR Service, Inc. The IRS recently released IRS Notice 2021-46, which provides new guidance and clarifications regarding the COBRA premium subsidy in the American Rescue Plan Act (“ARPA”). This notice follows an earlier release of IRS FAQs in Notice 2021-31. Notice 2021-46 provides background information about the COBRA premium assistance, addresses several questions with specific examples and […]

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Six Employer Questions to Answer Before Imposing a Surcharge on Unvaccinated Workers

READ TIME: 5 MINUTES Many employers are struggling to increase COVID-19 vaccination rates among their workforce, concerned not only about both the safety of the workforce but also the costs of COVID-19 treatment that could be avoided through vaccination. Some are now turning to the possibility of a higher premium cost, or surcharge, for any […]

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Departments Defer Transparency and Disclosure Rule Enforcement, Provide FAQ Guidance

READ TIME: 8 MINUTES On August 20, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury (collectively, the Departments), issued FAQ guidance regarding provisions of the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations Act, 2021 (CAA). Specifically, the FAQ provide guidance to group health plans […]

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Webinar: Best Practices for Handling IRS ACA Penalty Letters

Tuesday, September 14, 2021 2:00 p.m. ET / 11:00 a.m. PT Register Now The Affordable Care Act requires that applicable large employers (ALEs) provide minimum essential coverage to eligible employees, which is enforced by the IRS based on information reported in IRS Forms 1094 and 1095. In response to Form filings, the IRS may issue […]

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Departments Defer Transparency and Disclosure Rule Enforcement, Provide FAQ Guidance

READ TIME: 8 MINUTES On August 20, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury (collectively, the Departments), issued FAQ guidance regarding provisions of the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations Act, 2021 (CAA). Specifically, the FAQ provide guidance to group health plans […]

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New Filing Deadline for 2019 and 2020 EEO-1 Component 1 Data Collection

Source: HR Service The EEO-1 Component 1 report is a mandatory annual data collection that requires all private-sector employers with 100 or more employees, and federal contractors with 50 or more employees meeting certain criteria to submit demographic workforce data, including data by race/ethnicity, sex, and job categories. The deadline to submit and certify 2019 […]

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IRS Announces 2022 HSA and HDHP Amounts

READ TIME: 2 MINUTES These limits will differ depending on whether an individual is covered by a self-only or family coverage tier under an HDHP. The IRS’s new higher HSA contribution limit and HDHP out-of-pocket maximum will take effect January 1, 2022. HDHP deductible limits will increase for plan years that begin on or after […]

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Group Health Plans and Cybersecurity: DOL and OCR Guidance

READ TIME: 7 MINUTES In response to this heightened activity, the U.S. Department of Labor (DOL) recently issued its first ever formal cybersecurity guidance that includes best practices for ERISA fiduciaries to consider in guarding against cyber threats. For many group health plan sponsors, much of the guidance addresses issues and items that have long […]

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