Health and Welfare Team

The COVID-19 Outbreak Period has had numerous impacts upon benefit plans, extending timelines with which plans had to perform certain activities.

President Biden declared the end of the National Emergency effective May 11, 2023. Employers must plan now for the end of the Outbreak Period.

Yes Virginia, there really is a Santa Claus(e).

The telehealth exception to the rule that in order to make an HSA contribution, a participant must be enrolled in a High Deductible Health Plan requiring non-preventive benefits to meet the plan's deductible is extended.

It must be the holiday season. The IRS recently finalized new regulations providing that ALEs must furnish the Forms 1095-C to employees no later than 30 days after January 31st of each year. In the past, forms were due by January 31st unless an employer asked for an extension. It's now automatic.

The IRS has now released all of the 2023 benefit limits on October 21, 2022. Earlier this year, they also released the High Deductible Health Plan (HDHP) and Health Savings Account (HSA) limits.

The PCORI annual filing and fees were reinstated through 2029. That means that all employers (or their insurers in fully insured group health plans) must file the annual IRS Form 720 by July 31st of each year, regardless of their plan year.

Starting in 2007, the Tax Relief and Health Care Act of 2006 (TRHCA) requires that the IRS release the upcoming year’s new HSA limits prior to June 1st. Thus, we now have the 2023 HSA limits.

Employers that offer prescription drug benefits are required to provide an annual notice to all Medicare-eligible plan participants and qualified beneficiaries before October 15th of each year, the start of the Medicare open enrollment period. Most send it to all participants.

In August 2021 Delta Airlines announced that starting in 2022 it was imposing a $200 per month premium surcharge for any COVID-19 unvaccinated employee. Other employers quickly began asking if this was allowable under a myriad of employee benefit laws. The answer is "yes," but...

On the last possible workday on which to provide needed guidance before health plan sponsors had to fend for themselves on when the COBRA and HIPAA Outbreak Period ended, the Employee Benefits Security Administration, part of the US Department of Labor, issued Disaster Relief Notice 2021-01.

We provided information at the end of April, 2020 about the IRS' and DOL's determination that the "pause" button was hit on a number of regular timing and payment due dates relating to COBRA, health plan claims (including health care FSA claims), and HIPAA Special Enrollment Periods. Is it ending?

Much later than usual, the IRS released the 2020 retirement plan contribution limits. Earlier this year, they also released the High Deductible Health Plan (HDHP) and Health Savings Account (HSA) limits. We now also have the cafeteria plan, adoption credit, and transit benefit limits as well.