United States Department of Labor
President Donald Trump declared a national emergency due to the COVID-19 pandemic earlier this year. The national emergency took effect on March 1, 2020, and it has yet to expire. Following the national emergency declaration came a wave of guidance and regulations, including guidance and regulations which impacted deadlines associated with employee benefit programs.
The U.S. Department of Labor (DOL) has issued guidance that will impact COBRA procedures, special enrollment periods, and claims procedures. The guidance will extend the length of certain time periods applicable to group health plans, disability plans and other welfare plans regulated by the ERISA law. Plan participants and beneficiaries will have additional time to do the following:
The Department of Labor (DoL), Department of Treasury (DoT) and the Department of Health and Human Services (HHS) have jointly proposed new rules that would impact Health Reimbursement Arrangements (HRAs) effective January 1, 2020.
New guidance was released on September 13, 2013 that applies to Health Reimbursement Arrangements (HRAs) and other employer healthcare arrangements. Much of the guidance impacts employers that want to provide reimbursements to employees to help pay for individual health insurance policy premiums. Many employers have given this idea some consideration instead of offering a traditional group health plan to reduce their costs.
The Affordable Care Act (ACA) requires non-grandfathered plans to impose limitations on out-of-pocket expenses for essential health benefits starting in 2014. The out-of-pocket limitations will be capped next year at $6,350 for single coverage and $12,700 for family coverage.
However, some self-funded plans will be exempt from this requirement until 2015. The guidance indicates that self-funded plans contracting with multiple service providers can delay this requirement for one year.
Most employers will be required to provide a written notification to employees in regards to the ability to access coverage through the new Health Insurance Marketplaces, also known as the exchanges. Even employers that don't provide coverage to their employees will be required to provide this written notification.
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