Tri-Agencies Provide Additional At-Home COVID-19 Testing Coverage Guidance

RYAN KADEVARI and JENNIFER TRUONG, February 22, 2022  On February 4, 2022, the Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments) released additional guidance concerning group health plan and health insurance coverage of over-the-counter COVID-19 diagnostic tests (“OTC Tests”). The guidance complements an initial set of FAQs previously issued […]

Health Plans and Insurers Required to Cover At-Home COVID Tests

MARY E. POWELL, January 11, 2022  On January 10, 2022, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) issued FAQs Part 51 (FAQs) regarding the requirement for health plans to cover over-the-counter (OTC) COVID-19 diagnostic testing (“OTC COVID Tests”). This will be required effective with OTC COVID Tests purchased on and after […]

Delay of Some Key Provisions of the Consolidated Appropriations Act and the Affordable Care Act’s Transparency Requirements

MARY E. POWELL, August 31, 2021  On August 20, 2021, the Departments of Labor (DOL), Health and Human Services (HHS) and Treasury (collectively, the Departments), issued Frequently Asked Questions (FAQs) regarding the implementation of certain provisions of the Consolidated Appropriations Act, 2021 (CAA) and the Affordable Care Act (ACA). Fortunately, several of the most complicated […]

IRS Guidance on COBRA Premium Assistance — What We Know Now

SARAH KANTER, July, 2021  After the passage of the American Rescue Plan Act of 2021 (ARP) and release of DOL model notices and FAQs on April 7, 2021, employers and other plan sponsors were still left with many open questions regarding the implementation of COBRA premium assistance. The IRS provided clarity to many of these […]

IRS Q&As Clarify COVID-19 Partial Plan Termination Relief

BRYAN J. CARD, June, 2021  On April 27, 2021, the Internal Revenue Service (IRS) published guidance in the form of five questions and answers (the “Q&A Guidance”) on the partial plan termination relief provided under the Consolidated Appropriations Act, 2021 (the “Act”), which was signed into law on December 27, 2020. This partial plan termination […]

American Rescue Plan Act: COBRA Subsidy Relief and Dependent Care FSA Limit Increase

ELIZABETH LOH, March 18, 2021   On March 11, 2021, President Biden signed into law the American Rescue Plan Act (the “Act”). This $1.9 trillion legislative package provides significant pandemic relief. This article focuses on the COBRA continuation coverage subsidy relief, as well as increased Dependent Care Flexible Spending Account (“Dependent Care FSA”) relief provided under […]

New FAQs Clarify Coverage Requirements for COVID-19 Testing and Vaccines

MARY E. POWELL and SARAH KANTER, March 1, 2021   On February 26, 2021, the Departments of Labor, Health and Human Services (HHS) and Treasury (collectively the “Departments”) released FAQs About Families First Coronavirus Response Act (the “FFCRA”) and Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”) Implementation Part 44 (the “FAQs”).1 These FAQs […]

Outbreak Extension Period — When Does It End?

MARY E. POWELL and SARAH KANTER, March 1, 2021   On February 26, 2021, the Department of Labor (DOL) issued Employee Benefits Security Administration (EBSA) Disaster Relief Notice 2021-01 (“2021 Relief Notice”)1, which explains how employee benefit plans must administer the end date of the tolling period for certain plan deadlines due to the COVID-19 national […]

An Overview of the Group Health Plan Provisions of the Consolidated Appropriations Act and the Final Transparency in Coverage Regulations

MARY E. POWELL and SARAH KANTER, January 29, 2021   The Consolidated Appropriations Act, 2021 (the CAA) contains numerous provisions that impact group health plans. At a high level, these CAA provisions can be broken into three main categories: (1) reducing Out-of-Network (OON) costs for enrollees, (2) providing transparency regarding costs, and (3) permissive changes that […]

Retirement Plan Relief in Consolidated Appropriations Act, 2021

T. KATURI KAYE and CATHERINE L. REAGAN, January 14, 2021   Signed by the President in December, the Consolidated Appropriations Act, 2021 (CAA) combines COVID-19 stimulus relief with a number of year-end appropriations bills, and it includes numerous provisions that will impact retirement plans. The retirement plan relief provisions in the CAA are divided between (1) […]

Flexible Spending Account Relief in Consolidated Appropriations Act, 2021

MARY E. POWELL and ELIZABETH LOH, January 6, 2021  In December, the President signed the Consolidated Appropriations Act, 2021 (CAA), which combines COVID-19 stimulus relief with a number of year-end appropriations bills. The CAA contains numerous provisions that will impact health and welfare plans. The provisions of the CAA that need immediate attention are the […]

New Proposed Rule Regarding Grandfathered Plans

SARAH KANTER, October 8, 2020  A new proposed rule (the “Proposed Rule”), released by the Departments of Treasury, Labor, and Health and Human Services (HHS) (the “Departments”) on July 10, 2020, would permit grandfathered group health plans and grandfathered group health insurance coverage (“grandfathered plans”) to make greater increases to certain types of cost-sharing requirements […]

IRS Guidance on Coronavirus-Related Distributions and Plan Loans

BRYAN J. CARD, August 27, 2020  On June 19, 2020, the Internal Revenue Service (IRS) issued Notice 2020-50 (the “Notice”), which provided much needed guidance on Section 2202 of the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”). Section 2202 of the CARES Act provides economic relief to certain individuals who have been […]

IRS Issues Coronavirus-Related FAQs for Retirement Plans and IRAs

ADRINE ADJEMIAN and ROBERT R. GOWER, June 8, 2020    On May 4, 2020, the Internal Revenue Service (IRS) issued a limited set of FAQs providing administrative guidance addressing the special “coronavirus-related distribution” (CRD) and plan loan provisions under the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). As anticipated, the guidance draws […]

The DOL Provides Limited Relief to Retirement Plans and Their Fiduciaries in Dealing with the COVID-19 Pandemic

RON ASSADI and NICHOLAS J. WHITE, May 18, 2020    In response to the COVID-19 pandemic (the “Pandemic”), on April 28, 2020, the Employee Benefits Security Administration (EBSA) issued Disaster Relief Notice 2020-01 (the “Notice”). The Notice addresses the following issues as impacted by the Pandemic: (i) deadlines for providing participant disclosures and notices; (ii) […]

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