Brian M. JohnstonBlog Posts
PCORI Fee Reminders and ClarificationsIRS Notice 2020-44 was issued this week as a reminder that Patient-Centered Outcomes Research Institute (PCORI) fees were extended under the Further Consolidated Appropriations Act of 2020 and are now not scheduled to expire until plan years ending after September 30, 2029. Annual PCORI fees will still need to be paid by insurers for employers...… Continue ReadingJune 11, 2020 |
New Model COBRA Notices and Emergency Extensions to COBRA Deadlines Require Employers to Take ActionThe Department of Labor (DOL) and other federal regulators released updates and clarifications related to employee benefits, including updates to model COBRA notices and an extension of certain statutory deadlines intended to minimize the possibility of participants and beneficiaries losing benefits during the COVID-19 pandemic. This article highlights the DOL’s recent changes and updates relating...… Continue ReadingMay 4, 2020 |
New Model COBRA Notices and Emergency Extensions to COBRA Deadlines Require Employers to Take ActionThe Department of Labor (DOL) and other federal regulators released updates and clarifications related to employee benefits, including updates to model COBRA notices and an extension of certain statutory deadlines intended to minimize the possibility of participants and beneficiaries losing benefits during the COVID-19 pandemic. This article highlights the DOL’s recent changes and updates relating... Continue Reading…May 4, 2020 |
Special COVID-19 Health Insurance Enrollment Windows and WaiversAs a result of the ongoing COVID-19 pandemic, we are observing all sorts of never-before-seen changes in the fully-insured group health plan space. Many insurers are liberally waiving their normal rules to accommodate the continuation of coverage to employers and employees in their time of need. Although the accommodations are welcome, employers need to exercise...… Continue ReadingMarch 24, 2020 |
Employee Benefits Issues to Consider Before Deciding to Furlough or Terminate Employees During the COVID-19 PandemicWith the combination of our nation’s response to COVID-19 and the resultant economic downturn, employers of all sizes face the moral and financial dilemma of evaluating employee headcounts while businesses are grappling with the reality of the current situation. Many employers are considering furloughs, or other types of approved leaves of absences, to reduce immediate...… Continue ReadingMarch 19, 2020 |
The IRS Addresses Expenses Related to COVID-19Like many other areas, employers are grappling with issues in response to the pandemic growth of the 2019 Novel Coronavirus (aka, “COVID-19”) in the workplace. One newer topic has been related to the desire to ensure employees and their families are proactively being diagnosed once symptoms present, to ensure proper care management for the employee...… Continue ReadingMarch 11, 2020 |
Association Health Plans – UpdateAs we advised was likely during our June 29, 2019 webinar, Association Health Plans—Are They Really an Option to Consider?, at least two states were likely to challenge the enforceability of the new regulations issued by the Department of Labor that expand the definition of “employer” for groups who are qualifying association health plans (“AHP’s”). ...… Continue ReadingJuly 27, 2018 |
Association Health Plans—Are They Really an Option to Consider?As discussed during our recent webinar, the finalized DOL regulations for qualifying “association health plans” will likely create new opportunities for sole proprietors and other primarily small businesses and other trade groups to band together in a coordinated manner to purchase more affordable health insurance as a “single employer” in 2019 and beyond. That said,...… Continue ReadingJuly 11, 2018 |
Your Not So Kind (or Welcome) Early Holiday Gift from the IRS: Letter 226jOn more than one occasion since passing the Affordable Care Act (“ACA”), the IRS has given some type of early holiday “gift” to alleviate pending compliance concerns for employers. One of the most significant of these occurred in late December 2015, when the IRS extended the mandated filing periods for Forms 1094/1095, which gave employers...… Continue ReadingDecember 1, 2017 |