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About this Blog
Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.Blog Contributors
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HDHP Telehealth Relief Extended for Remainder of 2022, but Mind the 3-Month Gap in Relief
On March 15, 2022, the Consolidated Appropriations Act, 2022 (the “2022 CAA”) was signed into law. Section 307 of the 2022 CAA extends the relief permitting high deductible health plans (“HDHPs”) to provide telehealth and other remote care services free … Continue reading
Group Health Plans Must Provide Free Over-the-Counter COVID-19 Tests Effective January 15, 2022
On January 10, 2022 the Departments of Labor, Health and Human Services, and Treasury issued Affordable Care Act FAQs Part 51 which addresses, in relevant part, payment for over-the-counter (“OTC”) COVID-19 testing. For more information about the OTC COVID-19 testing and its … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged covid, FFCRA, Health Care, health plans
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Free COVID-19 Vaccine and Testing Update
On November 30, Moderna announced that it is seeking FDA authorization for its COVID-19 vaccine. In addition, on November 17 the FDA issued an emergency use authorization for the first COVID-19 diagnostic test for self-testing at home. With these recent … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged covid, covid-19, fda, health plans, moderna, testing, vaccines
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IRS to Begin Enforcing 4980H Penalties on Large Employers Before End of 2017
On November 2, 2017, the IRS issued guidance regarding the enforcement of Employer Shared Responsibility payments, otherwise known as the Section 4980H penalty. Questions 55-58 of the IRS Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, Affordable Care Act, employer shared responsibility, health care reform, health plans, IRS, large employer penalties, minimum essential coverage
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“A Trap for the Unwary” – Does Your Self-Funded Health Plan Provide Transgender Benefits? It Might Need to Soon.
Assistant Secretary of Labor Phyllis Borzi recently offered informal guidance on the broad scope of nondiscrimination regulations proposed under Section 1557 of the Affordable Care Act. During her remarks at the ABA Labor Section Employee Benefits Committee Meeting in February, … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged ACA, Affordable Care Act, health care reform, health plans, nondiscrimination, proposed regulations, transgender
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IRS Issues More Guidance On Employers That Pay For Individual Health Insurance Policies for Employees – Gives Limited Relief to Small Employers
I have blogged more on the topic of how the Health Care Reform Act applies to employers that reimburse employers for individual health insurance policies than any other topic in the last year. At one point in time, as indicated … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, Health Care, health care reform, health plans, Notice 2015-17
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Health Care Reform 2015 – An Update
2015 is a significant year for health care reform because the large employer shared responsibility penalties under Internal Revenue Code Section 4980H take effect for most large employers. See our SW Benefits Update, “Health Care Reform’s Employer Shared Responsibility Penalties: A … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, Health Care, health care reform, health plans, king v. burwell, large employer penalties
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HHS Extends November 17 Deadline to Submit Covered Lives Data under Reinsurance Program
The Health Care Reform Act created the transitional reinsurance program, which requires most self-insured health plans to make contributions to HHS for the 2014, 2015, and 2016 calendar years, in an attempt to stabilize premiums in the individual market. The … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Health Care, health care reform, health plans, HHS, reinsurance program, self-insured health plans
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November 5 Deadline to Obtain HPID Delayed by HHS
On October 31, 2014, HHS announced a delay, “until further notice,” in the enforcement of the regulations pertaining to Health Plan Identifiers (HPIDs) and their use in HIPAA standard electronic transactions. For more information on the HPID requirements, please see … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged health plans, HIPAA, HPID
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Accurate Documentation of Welfare Plans May Save Employers Certain Costs and Headaches Down the Road
ERISA requires all pension and welfare benefit plans to be maintained in a written plan document. The DOL and several courts have taken a broad view of what constitutes a “written plan document,” and while pension plans are usually very … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged health plans, plan documents, welfare plans
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