Senate Rejects Proposals to Repeal and Replace the ACA
Early in the morning on Friday, July 28, 2017, the Senate, by a vote of 51-49, rejected the Health Care Freedom Act (HCFA), or “skinny repeal” of the ACA, which was the last-ditch effort of Senate Republicans to repeal and replace the ACA. In dramatic fashion, three Senate Republicans voted no on the measure, including Lisa Murkowski (AK), Susan Collins (ME) and John McCain (AZ), who cast his vote with an emphatic thumbs down. Sen. McCain appeared to be the difference-maker as he returned from his home state to the Senate floor just days after having announced his diagnosis with brain cancer. His “no” vote spelled defeat for the HCFA, as all Democrats and Independents voted no as well.
The week leading up to the vote brought all sorts of political twists and turns as Senate Republicans attempted to garner enough support to keep the ball on ACA repeal and replace moving forward. On Tuesday, McCain appeared to be the Republican hero, as he voted in favor of starting the Senate ACA repeal-and-replace debate. His vote, along with Vice President Pence’s tiebreaking vote, began 20 formal hours of debate on amendments to the American Health Care Act (AHCA, which is the version of ACA repeal and replace passed by the House back in June).
During the debate, the Senate also rejected the Better Care Reconciliation Act (BCRA, which was the Senate’s original ACA repeal-and-replace proposal), a 2015 bill that sought total repeal of the ACA, and several other amendments (including one relating to support of a single payer system). That all led to the last-effort vote on the HCFA, the actual text of which was not released until late on the evening of July 27, just hours before the final vote. The HCFA would have repealed only portions of the ACA (hence the “skinny repeal”), including the individual and employer mandates. The HCFA also included a provision giving states more flexibility through waivers. Senate Republicans who supported the HCFA had hoped they could pass the measure and then go to conference with House Republicans to come up with a final proposal that would go further in repealing and deeper in replacing the ACA. The votes of Sens. Murkowski, Collins and McCain dashed those hopes.
Following the vote, Senate Majority Leader Mitch McConnell (KY) expressed disappointment in the result, while Senate Minority Leader Chuck Schumer (NY) expressed relief. Both articulated interest in visiting a bipartisan approach for future discussion. Other congressional leaders also weighed in, including House Leader Paul Ryan, who expressed disappointment. President Trump tweeted to “let Obamacare implode, then deal.”
Looking forward, it appears the GOP effort to repeal and replace the ACA is dead, at least with respect to the budget reconciliation process. Republicans had hoped to use that process since it requires only a simple majority of 50 votes rather than the normal supermajority of 60 votes. It’s unclear how Republicans might proceed from here. There is the possibility of future legislation aimed at repealing and/or fixing the ACA, although those efforts would now require Democratic involvement and support. Already, though, senators and other members of Congress are presenting different ideas, both to the public and to the White House. Some potential bipartisan ideas include continued funding of the ACA subsidies, expanding state innovation waivers, allowing carriers to sell catastrophic coverage, fixes to reinsurance programs to help with high-cost enrollees and piecemeal changes to the ACA.
In addition to continued discussion in Congress, the Trump administration will also have to decide how they’ll enforce the ACA, particularly considering Trump’s executive order that asks federal agencies to relieve the burdens associated with ACA compliance. While the administration could perhaps relax or simplify some ACA rules, it couldn’t likely ignore enforcement altogether without the risk of some type of litigation.
For employers, the ACA remains the law of the land, as it has throughout this entire process. This means employers should continue with their compliance efforts, including (among other things) tracking hours and offering affordable coverage under the employer mandate, keeping records for related reporting and making PCOR and reinsurance payments that are due in 2017.
As always, we will continue to monitor the situation and report on developments.
IRS Releases 2017 Draft Versions of 6055 and 6056 Informational Reporting Forms
On July 28, 2017, the IRS released draft versions of the 2017 informational reporting forms that insurers and self-insured employers will use to satisfy their obligations under IRC Section 6055 and that large employer plan sponsors and health plans will use to satisfy their obligations under IRC Section 6056. These forms, once finalized, will be filed in early 2018 relating to 2017 information. The IRS is currently accepting comments on the draft forms. Instructions for the forms have not yet been released.
As a reminder, Forms 1094-B and 1095-B (6055 reporting) are required of insurers and small self-insured employers that provide minimum essential coverage. These reports will help the IRS to administer and enforce the individual mandate. Form 1095-B, the form distributed to the covered employee, will identify the employee, any covered family members, the group health plan and the months in 2017 for which the employee and family members had minimum essential coverage under the employer's plan. Form 1094-B identifies the insurer or small self-insured employer and is used to transmit the corresponding Form 1095-B to the IRS.
Forms 1094-C and 1095-C (6056 reporting) are to be filed by applicable large employers that are subject to the employer mandate (as they will help the IRS administer and enforce the employer mandate). Employers will use Form 1095-C to identify the employer, the employee, whether the employer offered minimum value coverage meeting the affordability standard to the employee and dependents, the cost of the lowest plan option and the months for which the employee enrolled in coverage under the employer's plan. Further, if the plan is self-insured, the employer will use the form to fulfill its Section 6055 reporting obligations by indicating which months the employee and family members had minimum essential coverage under the employer’s plan.
Whereas Form 1095-C reports coverage information at the participant level, Form 1094-C reports employer-level information to the IRS. The applicable large employer will use this form to identify the employer, number of employees, whether the employer is related to other entities under the employer aggregation rules and whether minimum essential coverage was offered.
The 2017 draft forms appear to have only a few minor changes compared to the 2016 forms. Highlights of the changes are as follows:
- 1094-B – Appears unchanged.
- 1094-C – Line 22, Option C, relating to “Section 4980H Transition Relief,” has been removed. This relief was only applicable to the 2015 plan year. Option C remained on the 2016 form as non-calendar-year plans may have qualified for this relief for some months in 2016.
- 1095-B and 1095-C – While there were no changes to the body of these forms, a new paragraph in the “Instructions for Recipient” section refers individuals to an IRS webpage (or IRS Healthcare Hotline) for additional information regarding the individual shared responsibility provisions, the premium tax credit and the employer-shared responsibility provisions.
Despite efforts to repeal and replace the ACA, it remains the law of the land, and employers will need to continue with ACA compliance until further notice. This means that large employers will need to continue to offer affordable, minimum value coverage to all full-time employees and prepare to comply with employer reporting requirements as to 2017 coverage.
Sixth Circuit Recognizes Business Records as Sufficient Proof of Notification of COBRA Rights
On June 30, 2017, the U.S. Court of Appeals for the Sixth Circuit, in Perkins v. Rock-Tenn Servs., Inc., 2017 WL 2829100 (6th Cir. 2017) , affirmed a ruling from the U. S. District Court for the Western District of Michigan, holding that a COBRA Election Notice had been properly sent to a former employee. The case was an employment discrimination lawsuit. In the district court case, the employee (Perkins) also claimed that the employer (Rock-Tenn) failed to send her an election notice allowing her to continue her health insurance benefits, as is required under COBRA. Rock-Tenn moved for summary judgment, which the district court granted as to all claims. Perkins appealed the decision to the U.S. Court of Appeals for the Sixth Circuit.
In affirming the lower ruling, the court found that even though neither hard copies of sent notices nor certificates of mailings were retained, there were sufficient computer and business records to demonstrate that the required notice had been provided.
In order to refute a claim for failure to offer COBRA, the employer must be able to show that an election notice was sent. In proving that the notice was sent, the DOL has said that the focus is on the reasonableness of the procedures used to furnish COBRA notices, and the analysis doesn’t require guaranteed delivery. Rather, plan administrators need only prove that the election notice was sent to the qualified beneficiary by a method that’s reasonably calculated to reach the qualified beneficiary.
With that in mind, the best proof would consist of a copy of the notice actually sent to the beneficiary, bearing each qualified beneficiary’s name or status and showing the address to which the notice was sent, plus proof that the notice was mailed to the address shown on the retained copy of the notice on a particular date. As this case demonstrates, however, this isn’t necessarily required. If an employer doesn’t keep a hard copy of the notice and proof of mailing, it would be wise to maintain significant business records (including possibly computer records) of the process used when issuing COBRA notices.
IRS Issues Form 14581-A (Fringe Benefits Compliance Self-Assessment for Public Employers)
On July 5, 2017, the IRS issued Form 14581-A, which is a tool for public employers (federal, state and local governments) to conduct self-assessments of their fringe benefits. Form 14581-A includes a total of 11 questions and has fillable check box and text fields so that the form can be completed electronically or printed and completed manually. This self-assessment tool is a general guide to the most common tax issues that public employers may encounter based on IRS audits, and it directs those entities to additional information as necessary.
As background, public employers have unique legal requirements for compliance with federal tax and Social Security laws. These employers need to be aware of the rules that apply to them and their workers (both employees and independent contractors).
Overall, the content of Form 14581-A is not completely unique to public employers; any employer seeking to conduct a self-assessment of its fringe benefits may find it helpful.
U.S. Treasury Announces Plans to Wind Down my RA Program
On July 28, 2017, the U.S. Department of the Treasury (“the Department”) announced that it will begin to phase out the my RA program over the coming months after a thorough review found it not to be cost effective. This review was undertaken as part of the Trump administration’s effort to assess existing programs and promote a more effective government. According to the Department, demand for and investment in the my RA program have been extremely low.
As background, the my RA program was a concept first introduced by President Obama in his January 2014 State of the Union address. The program was an option for individuals who didn’t have access to a retirement savings plan (e.g., 401(k) plan) at work. In addition to setting up contributions via direct deposit through an employer, individuals could set up one-time or recurring contributions to their my RA from a checking or savings account. Savers could also direct all or part of a federal tax refund to their my RA.
As shared in the Feb. 11, 2014, and Nov. 17, 2015, editions of Compliance Corner , features of the my RA program included:
- Low cost to employers. Employers didn’t administer or contribute to the accounts.
- Low investment barriers.
- Principal protection. The accounts were backed by the U.S. government, similar to savings bonds.
- Contributions could be withdrawn tax-free at any time.
- Individuals could keep the account if they changed jobs or could roll it over to a private sector plan.
Participants in the my RA program are being notified of the upcoming changes, including information on moving their my RA savings to another Roth IRA. Participants are encouraged to visit www.myRA.gov for additional information or to call my RA customer support with any questions.
It’s MLR Rebate Time Again!
PPACA requires insurers to submit an annual report to HHS that accounts for plan costs. If the insurer doesn’t meet the medical loss ratio standards, they must provide rebates to policyholders. Rebates must be distributed to employer plan sponsors between Aug. 1, 2017, and Sept. 30, 2017. Employers should keep in mind that if they receive a rebate, there are strict guidelines as to how the rebate may be used or distributed.
For more information, please contact your advisor for a copy of “ Medical Loss Ratio Rebates: A Guide for Employers ” or “ Medical Loss Ratio: PPACA’s Rules on Rebates .”
Is leaving incarceration or being incarcerated a qualifying event under a Section 125 Cafeteria Plan?
Assuming the employer allows pre-tax deductions through a cafeteria plan, leaving incarceration or being incarcerated would generally not be considered a qualifying event permitted under the Section 125 rules. As background, Section 125 only allows employees to make one election annually unless they experience a qualifying event. Becoming incarcerated or released from incarceration would only trigger a qualifying event under Section 125 if the incarceration affected plan eligibility or somehow gave rise to one of the other qualifying events.
Specifically, if the incarceration makes a dependent ineligible for coverage (perhaps under the carrier’s contract), the “dependent ceases to satisfy eligibility requirements” change in status event under Section 125 would possibly apply.
A “change in residence” event could also apply if the incarceration or release from incarceration somehow affected the individual’s eligibility (again, possibly stated under the carrier’s contract). In other words, the move to or from prison would have to affect the employee or dependent’s eligibility for coverage under the employer’s plan. For example, if an individual moved into the plan’s service area after he wasn’t in the plan’s service area while incarcerated, there would be an argument that a qualifying event would occur when he’s released. However, this event rarely applies because most plans (unless it’s an HMO) provide benefits for out-of-area/out-of-network services.
Additionally, there’s a HIPAA special enrollment right for those who lose other coverage. However, this special enrollment right applies to those who lose other group health coverage. So, if an individual were covered under some type of inmate health plan, then it wouldn’t likely be considered a group health plan and the enrollment right wouldn’t apply.
Therefore, if a participant’s or dependent’s plan eligibility isn’t altered by becoming incarcerated or leaving incarceration or by a change in residence, it appears no Section 125 event would apply and the employee could not change his/her election until the next open enrollment period, or until he/she experienced some other qualifying event. Thus, an employer should review the carrier contract for eligibility requirements and permit a change only if a qualifying event applies and the Section 125 plan document allows for it.
Also keep in mind that although leaving incarceration rarely permits an employee to make an election change under an employer’s Section 125 plan, an individual leaving incarceration does indeed experience a special enrollment period in the health insurance marketplace for purchasing individual coverage.
Limits on Participant Payments for Prescription Drugs at the Point of Sale
On July 10, 2017, Gov. Malloy signed SB 445 into law, creating Public Act No. 17-241. This law states that health plan issuers cannot require plan participants to pay for prescription drugs at the point of sale in an amount that exceeds the applicable copayment, the allowable claim amount or the amount they must pay if they don’t have health plan coverage or other source of drug benefits or discounts (whichever of those is lowest). An “allowable claim amount” is generally defined to mean the amount the issuer pays the pharmacies for prescription medications.
This law is effective Jan. 1, 2018. Although the law doesn’t impose any new employer compliance obligations, employers may want to be aware of the new requirements in case questions should arise regarding prescription drug costs for employees.
Treatment of Substance Abuse and Opioid Addiction
On June 30, 2017, Gov. Malloy signed HB 7052 into law, creating Public Act. No. 17-131. The new law requires plans that provide coverage to plan participants who are diagnosed with substance use disorders (which includes opioid addiction) to provide coverage for medically necessary and monitored detoxification services and for medically necessary and medically managed intensive inpatient detoxification services. The law defines “medically monitored detoxification services” and “medically managed intensive detoxification services” by the most recent edition of the American Society of Addiction Medicine (ASAM) Treatment Criteria for Addictive, Substance-Related and Co-Occurring Conditions. More information on ASAM can be found here.
In addition, plans may not establish terms, conditions or benefits that place a greater financial burden on plan participants for diagnosis or treatment of mental or nervous conditions than that which they provide for medical, surgical or other physical health conditions. Finally, plans must provide direct reimbursement for diagnosis and treatment of substance use disorders for covered services provided in Connecticut by out-of-network health care providers. Reimbursements must be allowed for multiple screenings as part of a single-day visit and to health care providers or multi-care institutions.
The new law contains no new employer obligations. But employers should acquaint themselves with the new rules for health plans and carriers. Generally speaking, employers should treat mental health conditions the same as physical health conditions. Not only does that help avoid potential discrimination problems, but also helps address the general countrywide trend of mental health awareness.
The new law is effective Jan. 1, 2018.
Coverage and Definition of Infertility Expanded
On June 20, 2017, Gov. Malloy signed HB 7124, creating Public Law No. 17-55. The new law expands the definition of “infertility” to mean conditions affecting plan participants who cannot conceive, produce conception or sustain a successful pregnancy during a one-year period, regardless of the insured’s health status. Prior law included the term “presumably healthy,” which potentially excluded those who may be unhealthy and unable to conceive. The law’s summary indicates that one potential class of “unhealthy” participants could be individuals with cancer, with the goal at expanding the “infertility” definition to include that class. Overall, the expanded definition takes effect Jan. 1, 2018.
Under current law, fully insured plans in Connecticut must provide coverage for infertility. Importantly, though, there is a religious employer exemption — employers that are organized to promote religious beliefs (such as churches or church-affiliated organizations) aren’t required to offer plans that provide coverage for diagnosis and treatment of infertility (if that practice conflicts with the employer’s religious beliefs).
The law contains no new employer compliance obligations, but awareness of the law will help employers address potential employee questions with respect to the definition and coverage of infertility.
Network Access and Adequacy
On July 12, 2017, Gov. Ige signed SB 387 into law. The new law requires insurers that offer network plans to maintain a network that is sufficient in numbers and appropriate in types of providers, including those that serve predominantly low-income, medically underserved individuals. This is to ensure that all covered benefits will be accessible without unreasonable travel or delay. Covered participants must have access to emergency services 24 hours per day, seven days per week.
If the network doesn’t include a type of participating provider or has an insufficient number or type of providers to provide a specific covered benefit to a participant without unreasonable travel or delay, the benefit must be paid at in-network levels.
Insurers must electronically post a current and accurate provider directory, which must be updated at least monthly. The general public must be able to view the directory without creating or accessing an account or entering a policy number.
The law is generally effective for policy years beginning on or after Jan. 1, 2019.
Mandated Leave and Accommodations for Victims of Domestic Violence
On March 8, 2017, Gov. Sandoval signed SB 361 into law (an act related to domestic violence), which effectively amends Chapters 608 and 613 of the Nevada Revised Statutes. This act generally requires Nevada employers to provide leave and reasonable accommodations for employees who are victims of domestic violence or whose family members are domestic violence victims. It also imposes recordkeeping requirements and prohibits certain discriminatory actions against these employees.
An employee who has been employed for at least 90 days may take up to a maximum of 160 hours of leave within 12 months immediately following the domestic violence occurrence. The leave hours may be paid or unpaid and can be used consecutively or intermittently. Domestic violence leave must be deducted from any applicable FMLA leave if the leave is used for a purpose that is also permitted under FMLA and the employee is otherwise eligible for FMLA. An employee may use leave hours for diagnosis, care or treatment of a health condition, or to receive counseling or assistance related to an act of domestic violence committed against the employee or family/household member of the employee.
Additionally, an employer must provide reasonable accommodations for these applicable employees. Examples of reasonable accommodations include work reassignments or transfers, modified schedules, a new work telephone number or any other accommodation necessary to ensure the safety of the employee and of the workplace, as long as it doesn’t create undue hardship. However, an employer may require the employee to provide documentation to substantiate any requests for accommodation.
An employer must maintain a record of the hours of leave taken under the law for each employee for a two-year period following the entry of the record, and must make those records available for inspection by the Labor Commissioner. The Nevada Labor Commissioner has posted an online bulletin describing the rights and benefits under the law. Employers are required to post the bulletin in a conspicuous location in each workplace maintained by the employer.
The Act related to domestic violence leave becomes effective Jan. 1, 2018. Thus, employers located in Nevada should review existing leave policies and make any pertinent changes to ensure compliance.
Managed Care Plans and Substance Abuse Coverage
On June 29, 2017, Gov. Sununu signed SB 158 into law. The new law applies to managed care plans. Specifically, managed care plans that provide coverage for substance use disorder services and have authorized or otherwise approved medication-assisted treatment for such services cannot require plan participants to renew those authorizations more frequently than once every 12 months. The law is effective Aug. 28, 2017.
Clarifications to Paid Sick Time Law
In June 2015, Gov. Brown signed SB 454 into law, which made Oregon the fourth state to require paid sick leave for employees beginning Jan. 1, 2016. However, since the law’s inception, there has been some confusion around certain aspects of implementation. Thus, in an effort to address ambiguity, Gov. Brown signed SB 299 into law on June 29, 2017, which makes clarifications and amendments to the paid sick time law.
As background, employers located in Oregon with 10 or more employees (six if located in a city with a population exceeding 500,000 [i.e., Portland]) must provide up to 40 hours of paid sick leave each year. Employers with fewer than 10 employees (six employees if located in a city with population exceeding 500,000) are required to give 40 hours of unpaid protected sick leave to eligible workers. Paid sick leave begins to accrue at a rate of one hour for every 30 hours of actual work. Employees begin accruing sick leave immediately upon hire, although they cannot use the leave time until 91 calendar days after date of hire.
Although not exhaustive, the following are some of the most notable amendments to the state paid sick leave law:
- Employers may now cap employees’ sick leave bank to 80 hours maximum, and may also limit employees’ accrual to up to only 40 hours of sick time per year.
- Employers with a current PTO policy that is equivalent or more generous than the minimum requirements must make sure to comply with the state leave requirements for the first 40 hours provided each year, but would not need to comply beyond the first 40 hours provided under the PTO policy.
- Seasonal farm stands or temporary construction trailers used for office purposes that are located in the Portland area are exempt from the lower employee count (i.e., those located in Portland with six or more employees).
- When determining the number of employees employed by an employer, certain individuals need not be included in the employee count. These individuals include directors of a corporation, members of an LLC, partners of an LLP and sole proprietors if these individuals have a substantial ownership interest in the business (i.e., more than 15 percent or a percentage equal to or greater than the average of other owners). These individuals’ family members (spouses, children, parents) may also be excluded.
- If an employee is paid hourly, weekly, monthly or on a piece-rate basis or commission basis, employers must pay any leave time used at the same rate of the employee’s hourly, weekly or monthly wage or the state minimum wage (whichever is greater).
FAQs intended to assist employers with compliance are now available online. The new amendments are effective as of Jan. 1, 2018. Employers located in Oregon should review their leave policies and ensure they are in line with the new and existing requirements under the state’s paid sick leave law.
Coverage for Medically Necessary Non-Opioid Treatments for Pain
On July 10, 2017, Gov. Raimondo signed SB 789 into law. Under the new law, plans issued in Rhode Island must provide coverage for medically necessary, evidence-based, non-opioid treatments for pain. Those treatments may include chiropractic care and osteopathic manipulative treatments performed by certain licensed individuals.
The new law is effective for plans issued, delivered or renewed on or after April 1, 2018. Employers with plans issued in Rhode Island should familiarize themselves with the new law to better understand the coverage they’re offering employees and to address employee questions relating to pain treatment and services.
Coverage and Definition of “Infertility” Expanded
On July 5, Gov. Raimondo signed SB 821 into law. The new law expands the coverage and definition of “infertility” for plans issued in Rhode Island. Specifically, plans that provide coverage for pregnancy-related benefits must provide coverage for medically necessary expenses related to the diagnosis and treatment of infertility for female plan participants ages 25 to 42 and for standard fertility preservation services when medically necessary treatments can directly or indirectly cause iatrogenic infertility to plan participants.
For this purpose, “infertility” under prior law meant the inability of otherwise presumably healthy married individuals to conceive or sustain a pregnancy during a one-year period. The new law adds to that definition by explaining that “standard fertility preservation services” means procedures consistent with established medical practices and professional guidelines established the American Society for Reproductive Medicine, the American Society of Clinical Oncology or other reputable professional organizations. In addition, “iatrogenic infertility” means impairment of fertility caused by chemotherapy, radiation, surgery or other medical treatments that affect reproductive organs or processes.
The new law contains no new employer compliance obligations, but employers should be aware of the infertility benefits available under their plans should employees have questions.
Coverage and Treatment of Domestic Partners
On July 18, 2017, Gov. Raimondo signed HB 5951 into law. Under the new law, employers and carriers may not treat plan participants who are in domestic partnerships differently than plan participants who are married. That fair treatment applies for purposes of premiums, policy fees or rates charged for health insurance policies. For purposes of the law, “domestic partnership” means two plan participants who are in exclusive, intimate and committed relationships with each other and who certify (by affidavit or some other signed document) that their relationship is one of domestic partner. Specifically, the two must certify that both plan participants are at least 18 years old and mentally competent to enter into a contract, aren’t currently married to someone else and aren’t related by blood (to a degree prohibited by Rhode Island law). In addition, the two must certify that they reside together (and have for at least one year before the affidavit is certified) and are financially interdependent. The new law applies to policies that are issued or renewed on or after Jan. 1, 2018.
Rhode Island employers should review their policies and plan offerings to ensure they are prepared to treat domestic partners the same as other married plan participants. That includes reviewing plan documents and other plan-related materials to ensure processes are in place to avoid any hint of discrimination against employees who are in a domestic partnership relationship.
Coverage for Mental Health/Substance Use Mandated in Small Group and Individual Market
On June 14, 2017, Gov. Abbott signed HB 10 into law. This law requires plans in the small group and individual market to provide treatment for mental health and substance use disorder (MH/SUD) treatment. Specifically, plans must provide MH/SUD coverage under the same terms and conditions that apply to medical/surgical coverage.
Similar to the federal Mental Health Parity legislation, plans also cannot impose quantitative or nonquantitative limitations on MH/SUD coverage that are more restrictive than those imposed on medical/surgical coverage.
This law takes effect on Sept. 1, 2017, and will apply to all plans delivered, issued for delivery or renewed on or after Jan. 1, 2018.
This material was created by PPI Benefit Solutions to provide accurate and reliable information on the subjects covered but should not be regarded as a complete analysis of these subjects. It is not intended to provide specific legal, tax or other professional advice. The service of an appropriate professional should be sought regarding your individual situation. PPI does not offer tax or legal advice. "PPI®" is a service mark of Professional Pensions, Inc., a subsidiary of NFP Corp. (NFP). All rights reserved.
Industry news topics covered in the Compliance Corner are chosen based on general interest to most employers and may include articles about services not available through PPI.
Is leaving incarceration or being incarcerated a qualifying event under a Section 125 Cafeteria Plan?