September 15, 2020
COVID-19 Updated Materials
Updated August 31, 2020: Benefits Compliance COVID-19 FAQ
Compliance Considerations on Insurance Carrier Refunds in the COVID-19 Environment
Updated September 4, 2020: COVID-19 State Quick Reference Chart
Reminder: Calendar Year SAR Must Be Distributed by September 30, 2020
Plans that are subject to ERISA and Form 5500 filing must distribute the Summary Annual Report (SAR) to participants within nine months of the end of the plan year; thus, a calendar year plan is generally required to distribute the SAR for the 2019 plan year by September 30, 2020. If the plan applied for an extension to the Form 5500 filing, the SAR is then due within two months following that filing.
The SAR is a summary of the plan’s information reported on the Form 5500. If a plan is not subject to Form 5500 filing, then it is exempt from the SAR notice requirement — this would include church plans, governmental plans and unfunded or insured plans with fewer than 100 participants. Also, large, unfunded self-insured plans are exempt from the SAR requirement even though they are subject to the Form 5500 filing requirement.
It’s MLR Rebate Time Again!
The ACA requires insurers to submit an annual report to HHS accounting for plan costs. If the insurer does not meet the medical loss ratio standards, they must provide rebates to policyholders. Rebates must be distributed to employer plan sponsors between August 1, 2020, and September 30, 2020. 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.
Reminder: Medicare Part D Notice to Employees Deadline Is October 14, 2020
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, 2020. This notice serves to put Medicare-eligible individuals on notice 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 an actuarial analysis. Also keep in mind that CMS provides a model notice for employers.
For more information, please download Medicare Part D Guidance for Employers.
We have an employee who has been out on long-term disability for several months. When can we terminate them?
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