PPI Benefit Solutions

COVID-19 Updates

IRS Clarifies Extension of Certain COBRA Election and Premium Payments Deadlines

On October 6, 2021, the IRS issued Notice 2021-58, clarifying the application of the extensions of timeframes related to COBRA. As a reminder, the extension of certain timeframes for employee benefit plans, participants, and beneficiaries required plans to disregard the period from March 1, 2020, until 60 days after the end of the National Emergency (known as the “Outbreak Period”) for certain deadlines, including the deadlines applicable to COBRA notices and payment. Subsequent guidance clarified that the relief is available from the earlier of a) one year from the date an individual or plan is first eligible for relief or b) the end of the outbreak period.

Notice 2021-58 clarifies that the disregarded period for an individual to elect COBRA continuation coverage and the disregarded period for the individual to make initial and subsequent COBRA premium payments generally run concurrently. This means that individuals who take advantage of the extension of certain timeframes by electing COBRA continuation coverage outside of their initial 60-day COBRA election timeframe will have one year and 105 days after the date the COBRA notices was provided to make the initial COBRA premium payment. (The 105 days represents the number of days until the first payment must be made under normal COBRA rules – an initial 60 days to make an initial COBRA election plus the 45 days to make the initial COBRA premium payment.)

Alternatively, individuals who make their COBRA election within their initial 60-day COBRA election period will have one year and 45 days to make the initial COBRA premium payment.

However, the notice also provides additional relief stating that initial COBRA premium payments will not be due before November 1, 2021, as long as the individual makes their initial COBRA premium payment within one year and 45 days after their election date. They provided this relief because some individuals might not have realized that the disregarded period to make a COBRA election and the disregarded period to make an initial COBRA premium payment run concurrently. In order to avoid inequitable outcomes, in no event will an individual be required to make the initial COBRA premium payment before November 1, 2021, even if November 1, 2021, is more than one year and 105 days after the date the election notice was received.

The notice also discusses the interaction of the extension of certain timeframes with the COBRA premium assistance provided under the American Rescue Plan Act (ARPA). Specifically, the extension of certain timeframes did not provide additional time for individuals to elect ARPA extended coverage. However, individuals will still be able to access the extension of timeframes relief to pay for any COBRA coverage that they receive after the ARPA COBRA premium assistance ends.

The notice goes on to provide a number of examples of how this guidance applies. Employers should review this notice to understand the relief it provides to individuals who will elect COBRA through the end of the outbreak period.

Notice 2021-58 »

CMS Issues FAQs Regarding COVID-19 Vaccine Premium Surcharges and Incentives

On October 4, 2021, the Departments of Health and Human Services, Treasury, and Labor (collectively, the departments) issued guidance in the form of FAQs clarifying HIPAA nondiscrimination rules applicable to certain vaccine-related wellness programs, as well as vaccine coverage. With the ongoing COVID-19 pandemic and the availability of vaccines, many employers are considering ways to incentivize their employees to get vaccinated. This recent guidance clarifies how HIPAA nondiscrimination rules impact wellness programs that offer vaccine-related premium surcharges and incentives.

In Q3 of the FAQs, the departments confirm that a group health plan is permitted to offer participants a premium discount for receiving a COVID-19 vaccination if the design of the program complies with federal wellness program rules. This includes HIPAA wellness plan rules applicable to health-contingent, activity-only wellness programs, the Americans with Disabilities Act (ADA), and other rules such as the ACA’s employer mandate affordability rules.

The HIPAA nondiscrimination rules require, among other things, that the program is reasonably designed to promote health or prevent disease, additionally:

The reward (together with any other rewards for other health-contingent wellness programs) must not exceed 30% (or 50% for tobacco-related wellness programs) of the total cost of employee-only coverage.
A reasonable alternative standard be available to those who show that it is unreasonably difficult to comply due to a medical condition (or medically inadvisable to satisfy the otherwise applicable standard).
Disclosure of the reasonable alternative in all plan materials describing the wellness program.

Furthermore, HIPAA prohibits excluding COVID-19 treatment for unvaccinated participants, as doing so would constitute discrimination based on a health factor. Q4 of the FAQs clarifies that while there is an exception to the prohibition on discrimination based on a health factor for compliant wellness programs, such exception cannot be used to deny eligibility for benefits or coverage based on a health factor. The wellness plan exception applies only to premium discounts and similar cost-sharing modifications.

Further, Q5 of the FAQs explains the impact of any premium discount or surcharge related to COVID-19 vaccination status on ACA employer mandate affordability calculations. The guidance provides that since COVID-19 vaccination is not tied to tobacco use, the employer must use the higher premium amount for affordability purposes. In other words, the employer must treat all employees as if they are not vaccinated when calculating whether the offered coverage is affordable under the employer mandate.

Lastly, the guidance also confirms that plans and issuers must cover COVID-19 vaccines and their administration without cost-sharing once a vaccine is authorized under an emergency use authorization or approved under a Biologics License Application.

Employers seeking to adopt a wellness program providing incentives or surcharges related to COVID-19 vaccination status should be mindful of this guidance and consult with employment law counsel to ensure they are compliant with all applicable laws.

FAQs About Affordable Care Act Implementation Part 50, Health Insurance Portability and Accountability Act and Coronavirus Aid, Relief, and Economic Security Act Implementation »

HHS OCR Issues FAQs Regarding HIPAA and COVID-19 Vaccinations in the Workplace

On September 30, 2021, the Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) released guidance clarifying how HIPAA applies to disclosures and requests for information regarding an individual’s COVID-19 vaccination status.

The guidance reminds the public that HIPAA privacy provisions apply only to covered entities (e.g., health plans, certain health care providers, and health care clearinghouses) and business associates. These provisions determine when covered entities and business associates are permitted to use and disclose protected health information (PHI) that covered entities and business associates create, receive, maintain, or transmit.

As such, HIPAA does not prohibit employers from asking whether employees have received a COVID-19 vaccine. In addition, HIPAA does not prevent individuals from disclosing whether they have received a COVID-19 vaccine, as HIPAA does not apply to individuals’ disclosures about their own health information. The guidance further provides that HIPAA does not prohibit an employer from requiring employees to disclose COVID-19 vaccination status as HIPAA generally does not regulate what information can be requested from employees per terms of employment. Importantly, though, other federal and state laws may require certain privacy compliance measures (e.g., requiring documentation be kept confidential).

Finally, HIPAA generally prohibits covered entities and business associates from using or disclosing an individual’s PHI, except when an individual authorizes such disclosure (or otherwise permitted by HIPAA), which can include information about whether the individual has received a COVID-19 vaccine.

This guidance serves as a reminder to employers regarding the applicability of HIPAA to certain disclosures related to COVID-19 vaccination status. Employers should be mindful that although HIPAA rules often do not apply to certain disclosures, other federal and state laws may be applicable.

FAQs »
Press Release »

Healthcare Reform

IRS Releases Draft 2021 1094 and 1095 Forms Instructions

The IRS recently released the drafts of general instructions for Forms 1094-B/C and 1095-B/C. Earlier this year, the IRS released the 2021 draft Forms 1094-B/C and 1095-B/C, as we reported in an article in the June 10, 2021, edition of Compliance Corner.

Forms 1094-C and 1095-C are filed by ALEs to provide information that the IRS needs to administer the employer mandate penalties and eligibility for premium tax credits, as required by the ACA under Section 6056. Forms 1094-B and 1095-B are filed by minimum essential coverage providers (e.g., insurers and self-insuring employers) to report coverage information in accordance with Section 6055.

Overall, the majority of the formats and rules remain the same as those in the previous year, with minor additions. The draft Form 1095-C and its instructions added two new codes (1T and 1U) to report individual coverage HRAs (ICHRA). Code 1T applies to ICHRAs offered to the employee and spouse but not dependents, with affordability determined using the employee’s primary residence location zip code. Code 1U applies to ICHRAs using the employee’s primary employment-site ZIP code affordability safe harbor.

For the 2021 reporting deadlines for applicable large employers (ALEs), an ALE must furnish a Form 1095-C to each full-time employee by January 31, 2022; and must file the Forms 1094-C and 1095-C with the IRS by February 28, 2022, or March 31, 2022, if filing electronically.

Importantly, the instructions do not mention an automatic extension to furnish statements to employees and other covered individuals. Instead, they explain how to request a discretionary 30-day extension. Moreover, the draft instructions do not discuss the good faith error penalty relief that was also provided in the prior years for reporting incomplete or incorrect information on the forms when reporting entities can show they made good-faith efforts to comply with the reporting requirements. Therefore, reporting entities should assume that the stated deadlines apply when preparing the required forms.

The draft instructions retain the same electronic filing threshold at 250 forms even though the IRS released the proposal recently to significantly reduce the filing thresholds so that more ALEs would be required to file electronically.

Keep in mind that the instructions and forms are still at the draft stage. Additional changes are possible in the final forms and instructions. We will keep you updated when the finalized 2021 forms and instructions are released in the future.

Draft Instructions for Forms 1094-C and 1095-C »
Draft Instructions for Forms 1094-B and 1095-B »
Draft Form 1094-B »
Draft Form 1095-B »
Draft Form 1094-C »
Draft Form 1095-C »

Federal Updates

Agencies Publish Interim Final Regulations Regarding Surprise Billing Arbitration

On September 30, 2021, HHS, the DOL and the Treasury Department released Part II of interim final rules implementing the No Surprise Billing Act (the Act) that was part of the Consolidated Appropriations Act, 2021 passed by Congress in late 2020. This set of interim rules focus on the independent dispute resolution process (IDR) between the payer and provider outlined in the Act, good faith cost estimates for the uninsured, the dispute resolution process for patients and providers, and rights to external review. Part I of these rules was published in July and is discussed in our July 8, 2021, article in Compliance Corner.

An interim final rule is a rule that an agency promulgates when it finds that it has good cause to issue a final rule without first issuing a proposed rule. Although interim rules are often effective as of the date of their publication, they will have a comment period after which the interim rule may be amended in response to public comments. In this case, the interim final rules are effective 60 days from the date they are published in the Federal Register. The 60 days serve as the comment period for the interim final rules.

IDR Process
The rules describing the IDR process are effective beginning January 1, 2022. They apply to out-of-network providers, facilities, providers of air ambulance services, plans, and issuers in the group and individual markets who need to determine the out-of-network rate for those items and services for which balance billing was prohibited under Part I of the rules.

Under these rules, payers and out-of-network providers have 30 days to negotiate privately to resolve a payment dispute. This “open negotiation” period starts when a provider notifies the payer in writing of its desire to initiate proceedings within 30 days of initial payment or denial from the payer. If the parties fail to settle the matter in that time, then either party can begin the IDR process within four days after the initial 30-day window closes. The parties then may jointly select a certified independent dispute resolution entity (which must certify that it has no conflict of interest with either party) to resolve the dispute (the “arbiter”). Note that if the parties cannot agree to an arbiter, then federal officials will select one.

Once the arbiter is selected, the parties will submit their offers for payment along with supporting documentation. The arbiter works from the presumption that the qualified payment amount (QPA) is the appropriate out-of-network amount for the item or service. The QPA is the insurance plan's median contracted rate for the same or similar service in an area, so the offer of payment closest to the QPA will usually be awarded. However, the arbiter must consider any credible documentation submitted to it by a party, and if it clearly demonstrates that the value of the item or service is materially different from the QPA, then the arbiter can deviate from the offer closest to the presumptive amount. The arbiter has 30 days to issue a binding written determination selecting one of the parties’ offers as the out-of-network payment amount. It should be noted that while both parties pay an administrative fee at the beginning of the IDR, the winning party gets this fee refunded.

The rules also provide a process to follow to become a certified independent dispute resolution entity. Applications must be submitted by November 1, 2021, if an entity wishes to be certified by January 1, 2022. More information about the process can be found here.

Good Faith Estimates for the Uninsured
The rules also require providers and facilities to provide a good faith estimate of the expected charges for items and services to an uninsured individual (or individuals that choose to pay for the item or service themselves). The good faith estimate must include expected charges for the items or services that are reasonably expected to be provided together with the primary item or service, including items or services that may be provided by other providers and facilities.

Since it will take time for providers and facilities to develop procedures for determining good faith estimates and providing them to the uninsured, HHS will exercise its enforcement discretion in situations where a good faith estimate provided to an uninsured (or self-pay) individual does not include expected charges from other providers and facilities that are involved in the individual’s care, for good faith estimates provided to uninsured (or self-pay) individuals from January 1, 2022, through December 31, 2022.

Dispute Resolution Process for Patients and Providers
When an uninsured individual receives a good faith estimate, but the ultimate bill is a substantially higher amount (which is defined in Part I of these rules, but generally is an amount at least $400 more than the good faith estimate), then Part II provides a dispute resolution process by which the uninsured individual can challenge the billing.

External Review
Part II expands on rules previously issued by the Departments regarding external review of claims and appeals. The original rules require plans to provide an external review process that claimants can follow when they receive final internal adverse benefit determinations. The new rules allow claimants to follow this process when they receive determinations that involve whether a plan or issuer is complying with the surprise billing and cost-sharing protections under the Act and its implementing regulations as well. The new rules also extend this requirement to grandfathered plans, but only to the extent that a claimant receives a determination related to the Act.

Employers should be aware of these new regulations, as they would have an impact on how self-insured plans are administered as well as how carriers interact with providers in fully insured plans.

Retirement Update

IRS Releases Issue Snapshot on Deemed Distributions of Participant Loans

On September 28, 2021, the IRS released an issue snapshot on deemed distributions of participant loans. Issue Snapshots represent the IRS’ periodic research summaries on tax-related issues. This snapshot discusses the compliance failures that will cause a participant loan from a retirement plan to be treated as a distribution for tax purposes.

Regulations require participant loans to meet certain requirements. Namely, loans must be operated pursuant to a legally enforceable agreement that provides a repayment schedule with level payments that occur no less frequently than quarterly. The loans must be limited to the lesser of $50,000 or the greater of 50% of the participant’s vested benefit or $10,000. The loan repayment term must also be limited to five years.

If those requirements are not met, then a deemed distribution occurs and the participant will have to pay taxes on the loan amount. The snapshot discusses the cure period that a participant may avail themselves of in the event of a late payment and the CAREs Act relief that allowed participants to take larger loans.

The snapshot provides tips to employers on how to comply with the retirement plan rules and indicates how an IRS investigator would approach certain compliance failures.

Deemed Distributions – Participant Loans »

Announcements

Reminder: Medicare Part D Notice to Employees Deadline Is October 14, 2021

Employers must notify individuals who are eligible to participate in their medical plan whether the plan’s prescription drug coverage is “creditable” or “non-creditable” as compared to Medicare Part D coverage.

As a reminder, the Medicare Part D notice of creditable coverage should be distributed to employees by October 14, 2021. This notice serves to inform Medicare-eligible individuals of whether or not their employer group coverage is creditable. That information is necessary to help such individuals avoid paying higher premiums (also known as late enrollment penalties) for Medicare Part D coverage.

Employers should consult with their service providers to determine whether their coverage is creditable using either the simplified determination method or actuarial analysis. Also, keep in mind that CMS provides a model notice for employers.

FAQ

Will the COVID-19 relief options for telehealth services continue to be available for the upcoming plan year?

The CARES Act and subsequent guidance provided plan sponsors with additional flexibility to offer telehealth services to participants. Generally, the relief was intended to ensure that healthcare services remained accessible to participants while minimizing the potential spread of COVID-19. Although some of the telehealth relief provisions have a set expiration date, others continue until the declared end of the COVID-19 public health emergency.

For example, the CARES Act allowed a high deductible health plan (HDHP) to cover telehealth services without a deductible or with a deductible below the minimum deductible normally required for an HSA-qualified HDHP. Importantly, such coverage could be provided even if the telehealth services were not related to COVID-19. Accordingly, plan sponsors could amend their plans to permit coverage of telehealth services before the statutory deductible was met, without these services being considered “impermissible” coverage for HSA eligibility purposes. As a result, participants of such amended HDHPs could continue to make HSA contributions while using the telehealth services.

Unfortunately, this temporary HDHP relief allowing for broad coverage of telehealth services is only available for plan years beginning on or before December 31, 2021. (Despite the immense popularity of this particular provision, no regulatory announcement has yet been made to extend the relief further.) Accordingly, the provision currently expires for calendar year plans on December 31, 2021. For non-calendar year plans, the relief would continue for the remainder of the plan year that ends in 2022. For example, the relief would extend through June 30, 2022, for a plan year beginning July 1, 2021.

The CARES Act also requires that group health plans cover COVID-19 testing without cost-sharing, whether provided via telehealth or otherwise. The plans must cover items and services provided to participants that result in administration of a COVID-19 diagnostic test for individual evaluation purposes. However, this requirement does not extend to testing for workplace surveillance purposes.

In separate guidance, the IRS stated that coverage of COVID-19 testing and treatment could be provided by a qualified HDHP prior to satisfaction of the statutory deductible, without such coverage being considered impermissible coverage. Therefore, participants could continue to contribute to HSAs while receiving such services. This relief was intended to reduce financial and administrative barriers to COVID-19 testing and treatment, whether provided through an in-person or telehealth visit.

The Cares Act requirement for coverage of COVID-19 testing without cost-sharing and the IRS relief (referenced in the preceding paragraph) remain in effect as the COVID-19 public health emergency continues. However, it is unclear if this IRS relief could apply to coverage for testing provided for other than individual diagnostic purposes; additional guidance would be welcome. Employers that sponsor HDHPs and wish to provide COVID-19 testing coverage without cost-sharing for workplace safety purposes should consult with counsel for guidance.

Additionally, COVID-19 relief was provided for a telehealth arrangement sponsored by a large employer (generally defined as an employer with over 50 employees) and offered only to employees or their dependents not eligible for coverage under any other group health plan offered by the employer (e.g., part-time employees). Under this relief, the telehealth arrangement is exempt from certain (but not all) ACA requirements, such as the prohibition on annual and lifetime limits and the preventive services mandate.

This relief extending telehealth services to otherwise ineligible employees is in effect for the duration of any plan year beginning before the end of the COVID-19 public health emergency. For example, if the emergency ends in June 2022, the relief would extend through the end of 2022 for a calendar year plan.

We will continue to monitor the regulatory guidance for further telehealth updates.

State Updates

Connecticut

October 12, 2021

Transitional Guidance Issued on Connecticut Family and Medical Leave Act Changes

The state Department of Labor recently provided guidance regarding amendments to the Connecticut Family and Medical Leave Act (CT FMLA) scheduled to take effect on January 1, 2022. Specifically, the release is designed to assist employers with administering leave during the transitional period from 2021 to 2022.

Under the current CT FMLA provisions, eligible employees are entitled to 16 weeks of leave in a 24-month period. Effective January 1, 2022, employees will be entitled to 12 weeks of leave in a 12-month period. Employees incapacitated by a serious health condition due to pregnancy may be entitled to an additional 2 weeks of leave.

According to the new guidance, if an employee commences leave in 2021, the duration of their leave as of January 1, 2022, would be limited to 12 weeks in the applicable 12-month measurement period that the employer uses (e.g., calendar year, rolling lookback or other method). This would be the case even if the employee was approved for and had already commenced 16 weeks of leave in 2021. Therefore, in 2022, the employer can look back over the applicable 12-month period to see if the employee has used any leave to determine if they have time available. Examples are provided for each of the four methods that may be used for calculating the 12-month period.

Employers should be aware of this update. However, the guidance does not have the binding force of regulations, which are anticipated to be released later this year. Accordingly, it is advisable for employers to consult with counsel for assistance regarding leave administration during this transition period, and any related updates to employee communications and leave policies.

Guidance concerning the transition to the new FMLA law on 1/1/22 when an employee has an already approved FMLA leave »

District of Columbia

October 12, 2021

Expansion of D.C. PFML Benefits; Extension of Offsetting Prohibition

As part of the Fiscal Year 2022 Budget Support Emergency Act of 2021, the following changes were made to D.C. Paid Family and Medical Leave benefits effective October 1, 2021 – September 30, 2022:

Paid medical leave increased from 2 weeks per 12 months to 6 weeks for leaves starting on or after September 26, 2021.
The normal 7-day unpaid waiting period is waived.
The benefit calculations increased based on the employee’s highest four-quarter earnings out of the most recent 10 quarters (as opposed to the previous calculation of the highest four quarters out of the most recent five quarters).
Miscarriage and stillbirth were added as qualifying reasons for medical leave.
Pre-natal leave was added as a new qualifying leave category providing two weeks of paid leave benefits.

The Emergency Act also extends the prohibition of short-term disability policies reducing benefits (also known as offsetting benefits) based on an insured’s receipt of medical leave benefits from the district. As previously reported, this prohibition was initially effective May 2021 and was temporary. Under the new law, the prohibition will remain in place until at least September 30, 2022.

The Department of Employment Services is expected to publish a revised PFML poster in the coming weeks. Employers should revise their leave policies as necessary.

D.C. Fiscal Year 2022 Budget Support Emergency Act of 2021 »

Hawaii

October 12, 2021

Gender Identity Benefit Explanations

On October 6, 2021, Insurance Commissioner Hayashida issued Memorandum 2021-13H, reminding insurers to post clear and complete explanations of coverage for gender identity services applicable to their plans prior to plan year 2022. Hawaii insurance regulations explicitly prohibit discrimination in health plans with respect to participation and coverage based on actual or perceived gender identity. This lines up Hawaii law with ACA Section 1557.

Employers with plans in Hawaii should familiarize themselves with this guidance.

Memorandum 2021-13H »

New Mexico

October 12, 2021

Cost-Sharing Prohibited for COVID-19 Boosters

On September 27, 2021, Superintendent Toal issued Bulletin 2021-020. This bulletin reminds carriers who issue plans regulated by the state that state rules prohibit cost-sharing for the diagnosis and treatment of COVID-19. This prohibition extends to COVID-19 booster shots. In addition, the bulletin reminds payers that COVID-19 testing remains exempt from cost-sharing obligations when the testing is medically appropriate as determined by a provider.

These prohibitions apply to all group plans and plans providing individual coverage, including self-funded plans, all group and individual insurers (including grandfathered and transition plans) on and off a Health Insurance Exchange, and to state and local government health plans.

Employers with plans regulated by the state should be aware of this development.

Bulletin 2021-020 »

Washington

October 12, 2021

Extension of Emergency Orders on COVID-19 Testing and Surprise Billing

On October 1, 2021, Commissioner Kreidler issued orders further extending emergency orders 20-01 and 20-06. Emergency Order 20-01, which has been extended through October 31, 2021, requires health insurers to waive copays and deductibles for COVID-19 testing. The order also requires insurers to allow a one-time early refill for prescription drugs.

Emergency Order 20-06, which has also been extended through October 31, 2021, protects consumers from receiving surprise bills for lab fees related to COVID-19 diagnostic testing. The order also encourages insurers to report out-of-network labs that are not publishing or honoring the cash price of COVID-19 diagnostic testing.

These orders apply to insurers but provide employers with information about the continued coverage of COVID-19 testing.

Further Extending Emergency Order 20-01 »
Further Extending Emergency Order 20-06 »

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.

PPI in the News Compliance Corner - October 14, 2021 Archive
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COVID-19 Updates

IRS Clarifies Extension of Certain COBRA Election and Premium Payments Deadlines

CMS Issues FAQs Regarding COVID-19 Vaccine Premium Surcharges and Incentives

HHS OCR Issues FAQs Regarding HIPAA and COVID-19 Vaccinations in the Workplace

Healthcare Reform

IRS Releases Draft 2021 1094 and 1095 Forms Instructions

Federal Updates

Agencies Publish Interim Final Regulations Regarding Surprise Billing Arbitration

Retirement Update

IRS Releases Issue Snapshot on Deemed Distributions of Participant Loans

Announcements

Reminder: Medicare Part D Notice to Employees Deadline Is October 14, 2021

FAQ

Will the COVID-19 relief options for telehealth services continue to be available for the upcoming plan year?

State Updates

Connecticut

October 12, 2021

District of Columbia

October 12, 2021

Hawaii

October 12, 2021

New Mexico

October 12, 2021

Washington

October 12, 2021

FAQ

Compliance Corner Archive

PPI in the News Compliance Corner - October 14, 2021 Archive You are here: Home / PPI in the News / Compliance Corner - October 14, 2021 Archive

COVID-19 Updates

IRS Clarifies Extension of Certain COBRA Election and Premium Payments Deadlines

CMS Issues FAQs Regarding COVID-19 Vaccine Premium Surcharges and Incentives

HHS OCR Issues FAQs Regarding HIPAA and COVID-19 Vaccinations in the Workplace

Healthcare Reform

IRS Releases Draft 2021 1094 and 1095 Forms Instructions

Federal Updates

Agencies Publish Interim Final Regulations Regarding Surprise Billing Arbitration

Retirement Update

IRS Releases Issue Snapshot on Deemed Distributions of Participant Loans

Announcements

Reminder: Medicare Part D Notice to Employees Deadline Is October 14, 2021

FAQ

Will the COVID-19 relief options for telehealth services continue to be available for the upcoming plan year?

State Updates

Connecticut

October 12, 2021

District of Columbia

October 12, 2021

Hawaii

October 12, 2021

New Mexico

October 12, 2021

Washington

October 12, 2021

FAQ

Compliance Corner Archive

PPI in the News Compliance Corner - October 14, 2021 Archive
You are here: Home / PPI in the News / Compliance Corner - October 14, 2021 Archive