The U.S. Department of Labor (DOL) has updated the model notice for employers to use to inform employees about the Children’s Health Insurance Program (CHIP). All employers with group health plans are required to distribute a CHIP notice at least once a year to employees living in certain states. There is no need to send another notice to workers who received the prior version in…

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Question: Is medical marijuana use protected by the Americans with Disabilities Act (ADA)? If so, what accommodations would be considered reasonable? Answer: You are not required to accommodate medical marijuana use under the Americans with Disabilities Act (ADA). Even though medical marijuana is legal in many states, under the federal Controlled Substances Act (CSA), marijuana is still illegal. The ADA expressly excludes people who use…

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Do you offer coverage to your employees through a self-insured group health plan? Do you sponsor a Health Reimbursement Arrangement (HRA)? If so, do you know whether your plan or HRA is subject to the annual Patient-Centered Research Outcomes Institute (PCORI) fee? This article answers frequently-asked questions about the PCORI fee, which plans are affected, and what you need to do as the employer sponsor….

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Curious about when you should notify a participant about a change to their health care plan?  The answer is that it depends!  Notification must happen within one of three time frames: 60 days prior to the change, no later than 60 days after the change, or within 210 days after the end of the plan year. For modifications to the summary plan description (SPD) that…

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States that permit carriers to renew medical policies without adopting various Affordable Care Act (ACA) requirements may continue to do so through 2019, according to a bulletin released April 9, 2018, by the U.S. Department of Health and Human Services. The bulletin extends transitional relief for non-ACA-compliant policies for another year. The affected category of non-ACA-compliant policies, available in some individual and small group insurance…

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Q. Can we provide summary plan descriptions (SPDs) electronically? A. Yes. However, just sending them is not enough to meet ERISA requirements; you must ensure the intended recipients are actually getting them. Specifically, ERISA requires SPDs to be furnished using “measures reasonably calculated to ensure actual receipt of the material” via “methods likely to result in full distribution.” Electronic delivery is one way to meet…

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IRS Releases Publication 15 and W-4 Withholding Guidance for 2018 On January 31, 2018, the federal Internal Revenue Service (IRS) released Publication 15 — Introductory Material, which includes the following: 2018 federal income tax withholding tables. Exempt Form W-4 New information on: Withholding allowance. Withholding on supplemental wages. Backup withholding. Moving expense reimbursement. Social Security and Medicare tax for 2018. Disaster tax relief. Read Publication…

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On March 6, 2017, the U.S. House of Representatives Ways and Means Committee released a proposed budget reconciliation bill, entitled the American Health Care Act, to replace portions of the Affordable Care Act (ACA). If enacted, the American Health Care Act would provide some relief from provisions of the ACA for employers and make other significant changes to employee benefits. While the proposal is 53…

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