Contacts
Limited Eleventh Hour Relief for Flexible Spending Accounts and Paid Leave, and the Inclusion of Surprise Billing Legislation
The Consolidated Appropriations Act, 2021 (the “Act”) was signed into law on December 27, 2020. The Act combines the $1.4 trillion omnibus federal spending package for the 2021 fiscal year and a $900 billion COVID-19 stimulus package.
The Act includes certain provisions affecting health and welfare benefits, including:
- Limited relief for flexible spending account plans;
- An optional limited extension to emergency paid sick leave (EPSL) and public health emergency leave under the emergency Family and Medical Leave expansion act (this leave is referred to as “EFMLEA” in this Alert);
- Student loan repayment assistance; and
- Surprise billing legislation.
This Alert summarizes these provisions based on the language of the Act and attempts to identify issues federal agencies should address in later guidance. No additional guidance was available as of this Alert’s publication date. We will also briefly touch on limited relief for qualified transportation fringe benefit plans unrelated to the Act. This Alert does not address the Act’s amendments to the Paycheck Protection Program.
Limited Flexible Spending Account Relief
The Act does provide flexible spending account relief, although it falls short of the relief participants wanted most. Except where noted, the relief generally applies to both health care flexible spending account plans (HCFSAs) and dependent care flexible spending account plans (DCFSAs). We will refer to these collectively as “FSAs” in this Alert. The IRS will likely release a notice or other guidance addressing various issues in January 2021.
Not What You Wanted
The limited relief does not permit FSAs (or their employer/plan sponsors) to refund unused FSA balances from the 2020 plan year.
Unlimited Carryovers
FSAs may permit participants to carry over their entire unused FSA balances from a plan year ending in 2020 to a plan year ending in 2021, and/or from a plan year ending in 2021 to a plan year ending in 2022.[1] If adopted, this relief overrides the existing $550 carryover limit applicable to HCFSAs and enables carryovers for DCFSAs.[2] This relief is available for both calendar and non-calendar year FSAs, but an unlimited carryover from the plan year ending in 2020 may be administratively impractical for many non- calendar year FSAs.
There is no IRS relief preventing a HCFSA carryover or grace period (including the extended grace period relief described below) in a general purpose HCFSA from interfering with an individual’s eligibility to make or receive contributions to a health savings account (HSA). We interpret the Act to permit unlimited carryovers from a general purpose HCFSA to a limited purpose or other HSA-compatible HCFSA. This can avoid potential HSA conflict for the following plan year.
Example: Assume an employer maintains FSAs with July 1 – June 30 plan years. The employer can amend its FSAs to permit unlimited carryovers from the July 1, 2019 – June 30, 2020 plan year to the July 1, 2020 – June 30, 2021 plan year, but it may be administratively difficult to do this so many months after-the-fact. The employer could limit its adoption of the unlimited carryover to the following FSA plan year, only permitting unlimited carryovers from the FSA plan year ending June 30, 2021 to the July 1, 2021 – June 30, 2022 plan year.
Additional Guidance Needed
Consistent with existing carryover rules, we assume the IRS will confirm:
- FSA carryovers do not count toward the following plan year’s annual contribution limits; and
- HCFSA carryovers do not affect the calculation of any applicable HCFSA COBRA premium for the following plan year.
Extended Grace Periods
FSAs may allow for grace periods of up to 12 months for plan years ending in 2020 and/or 2021. This relief is available for both calendar and non-calendar year FSAs but, similar to the unlimited carryover, an extended grace period may be administratively impractical in 2020 for many non-calendar year FSAs.
Note: An unlimited carryover seems administratively preferable to an extended grace period, because it does not require tracking of the remaining unused FSA balance from the prior plan year and allows greater flexibility to avoid potential HSA conflicts.
Additional Guidance Needed
Under the cafeteria plan rules, a HCFSA cannot use a grace period and carryover feature during the same plan year. The IRS temporarily made an exception as a part of COVID-19 relief released earlier this year (see our earlier Alert addressing this relief). We expect the IRS will address whether an FSA can adopt both the unlimited carryover feature and extended grace period for the same plan year under this relief – if there is any advantage to doing so – or if an FSA is limited to one or the other.
HCFSA Spend-Down Feature for Former Employees
HCFSAs may allow employees who terminate employment in 2020 or 2021 to spend down their unused balances for qualifying medical expenses incurred through the end of the HCFSA plan year without a COBRA election. For this purpose, a grace period – including the extended grace period described above
- counts as part of the HCFSA plan year. This relief does permit reimbursements for expenses incurred after termination.
The HCFSA uniform coverage rule does not apply to this spend-down feature, and HCFSA reimbursements are limited to a participant’s remaining unused balance (including available employer contributions or reimbursements).
Note: A spend-down feature already exists for DCFSAs, although employers rarely adopt it.
Modified DCFSA Age Limit
DCFSAs may (but see Additional Guidance Needed below) provide age limit relief under the following two circumstances:
- If a DCFSA participant’s child turned 13 during the last DCFSA plan year with an open enrollment period ending by or before January 31, 2020, the limiting age increases to 14 years old for the remainder of the DCFSA plan year in which the child aged out.
Example 1: Jack participates in his employer’s DCFSA for the January 1, 2020 – December 31, 2020 plan year. Open enrollment for this plan year occurred during November 2019, which was by or before January 31, 2020. Jack’s only eligible child turned 13 on August 20, 2020. Under this relief, Jack’s child remains eligible under the DCFSA for the remainder of the 2020 plan year. - Another age limit modification is available if a DCFSA participant has an unused balance at the end of the last DCFSA plan year with an open enrollment period ending by or before January 31, 2020, and the employee’s child turns 13 during the following DCFSA plan year.[3] In that instance, the limiting age increases to 14 years old for the following DCFSA plan year, and the unused balance remains available to reimburse for qualifying childcare expenses for that plan year. However, this increased age limit applies only to the unused balance and not any new DCFSA election made for the next plan year. This requires separate tracking of the two amounts.
Example 2: Misti participates in her employer’s DCFSA for the July 1, 2019 – June 30, 2020 plan year. Open enrollment occurred during June 2019, which was by or before January 31, 2020. Misti has a $1,400 unused balance as of June 30, 2020, and one of her children will turn 13 on September 15, 2020. Under this relief, the $1,400 balance remains available for qualifying childcare expenses for a child who is under 14 years old for the July 1, 2020 – June 30, 2021 plan year. Any new DCFSA election by Misti for that plan year will still be subject to the age 13 limit.
This relief may be administratively difficult for a number of non-calendar year DCFSAs, such as the DCFSA in Example #2.
Additional Guidance Needed
We assume the IRS will address or confirm the following:
- Based on the wording of the Act,4 whether this relief is optional or mandatory for employers and their DCFSAs;
- Whether an employee must actually elect DCFSA coverage for the following plan year in order to have access to the unused funds under the second age limit modification relief, or if the unused balance is treated as a carryover (this seems more likely);
- Whether the unused balance is available for reimbursements for any eligible child during the following plan year;
- Whether the following plan year also includes that plan year’s grace period, if any; and
- That the unused balance does not count toward the following DCFSA plan year’s annual contribution limit.
FSA Election Changes Permitted Without Qualifying Life Event
For plan years ending in 2021, FSAs may permit participants to make election changes without a corresponding qualifying life event (QLE). The Act appears to allow employers to limit the situations in which participants can increase or decrease elections similar to the “amnesty QLEs” we described in our earlier Alert.
Additional Guidance Needed
We expect the IRS will address employer flexibility to allow or limit election changes and will confirm employers can prohibit elections to reduce FSA coverage below amounts already reimbursed for the plan year.
Amendment Timing
The Act permits amendments for relief to be effective retroactive to the current plan year if adopted by the end of the first calendar year after the end of the current plan year. The plan must be administered consistently with the amendment from its intended effective date through its later adoption date.[5]
Example: ABC Company maintains calendar year FSAs. ABC Company must amend its FSAs no later than December 31, 2021 in order to permit unlimited carryovers from the 2020 to the 2021 plan year.
Note: The Act’s amendment timing rules do not cover the existing unlimited spend-down feature for DCFSAs. If an employer wishes to implement this feature for its DCFSA, it must do so prospectively and should begin to take steps to implement this feature before the next DCFSA plan year begins.
An Optional Limited Extension to EPSL and EFMLEA
Employers have the option to extend either EPSL, EFMLEA, or both from January 1, 2021 through March 31, 2021. This is not required. The rules that were in effect during the April 1, 2020 – December 31, 2020 EPSL/EFMLEA mandate period substantially remain in effect during the extension. An employer may continue to claim tax credits for paid leave taken by eligible employees during the extended period. The regular due date for IRS Form 941 for the 1st Quarter of 2021 is April 30, 2021.
If an employer adopts extended EPSL, EFMLEA, or both, it may be prudent to continue offering and administering the extended leave(s) on the same general terms as during the April 1, 2020 – December 31, 2020 period to avoid potential discrimination claims and/or employee relations issues. Please see our Coronavirus Update for Employers for more information about EPSL and EFMLEA.
But Something’s Missing
The Act does not grant additional leave time during the extended EPSL or EFMLEA period.
- Extended EPSL – It appears a full-time employee is only eligible for extended EPSL up to the number of unused EPSL hours remaining from the 80 hours available during the April 1, 2020 – December 31, 2020 period.
- Extended EFMLEA – The availability of extended EFMLEA is unclear. As originally drafted, up to 12 weeks of EFMLEA (≈10 weeks paid) were available from April 1, 2020 through December 31, 2020. EFMLEA was also limited by an employee’s remaining available FMLA leave. This raises the following questions:
- Is a full-time employee only eligible for extended EFMLEA if the employee did not exhaust his or her 12 weeks of EFMLEA (≈10 weeks paid) available from April 1, 2020 through December 31, 2020?
- Assume a full-time employee was unable to use all of his or her EFMLEA because s/he did not have 12 weeks of available FMLA leave from April 1, 2020 through December 31, 2020. If the employee’s available FMLA leave wholly or partially resets during the extended EFMLEA period, does the employee regain the unused EFMLEA for use?
- If the employee’s available FMLA leave wholly or partially resets during the extended EFMLEA period, does the employee gain new EFMLEA for use? This seems unlikely.
- Is a full-time employee only eligible for extended EFMLEA if the employee did not exhaust his or her 12 weeks of EFMLEA (≈10 weeks paid) available from April 1, 2020 through December 31, 2020?
Additional Guidance Needed
We expect the U.S. Departments of Labor (DOL) and Health and Human Services (HHS) to release new frequently asked questions or other guidance in January addressing:
- The availability and use of remaining or new leave during the extended EPSL and EFMLEA period;
- Whether an employer must extend EPSL/EFMLEA through March 31, 2020, or if the employer can adopt a shorter period; and
- Other issues related to the administration of extended EPSL/EFMLEA consistent with the rules that were in effect from April 1, 2020 – December 31, 2020.
Student Loan Repayment Assistance Extended
The CARES Act earlier amended Section 127 of the Internal Revenue Code to permit employers to pay up to $5,250 of an employee’s existing student loans (including interest) on a tax-free basis through an educational assistance program. The employer may pay the lender directly or reimburse the employee for the employee’s loan payments. This initially applied to student loan payments paid on or after March 27, 2020 through December 31, 2020. The Act extends the end date for student loan repayment assistance to December 31, 2025.
Note: Educational assistance programs are usually limited to reimbursement for an employee’s current tuition expenses, but a program may cover current tuition and/or loan repayment through 2025. The $5,250 limit applies to all tax-free educational assistance benefits provided by the employer for the year. Tax-free educational assistance program benefits require the employer to adopt an educational assistance program, and an existing program would need modified to permit payment for existing loans.
The No Surprises Act
Congress included long-awaited surprise billing legislation in the Act, and the portions of the No Surprises Act focusing on balance billing protection for patients and related disclosure requirements are more than 150 pages long.
When, Exactly?
The surprise billing protections are effective January 1, 2022. Certain disclosure requirements should also be effective on or about January 2022.
Highlights
The No Surprises Act includes the following provisions:
- Patients cannot be balance-billed for out-of-network emergency services. This protection applies from the initial evaluation until stabilization when the patient (or a representative) can consent to transfer to an in-network facility. The protection applies to both out-of-network facilities and out-of- network providers. This protection also applies to air ambulance services, but it does not apply to ground ambulance services.
- Patients can only be balance-billed for non-emergency services performed at an in-network facility by an out-of-network provider under certain circumstances. This protects patients who receive care at an in-network facility from surprise billing by an ancillary provider participating in the care or a specialist responding to an unexpected complication who is out-of-network. The most common examples of out-of-network ancillary providers are radiologists and anesthesiologists. Similarly, an out-of-network cardiologist might be necessary to respond to a surgical complication.
A patient can waive this protection by consent if notified at least 72 hours in advance of the care. The No Surprises Act contains other limited exceptions.
- A dispute resolution procedure that includes binding arbitration to resolve conflict between health plans and out-of-network providers regarding the plan’s payment for out-of-network care.
- Various cost estimate, transparency, and other disclosures.
To be Continued…
Due to the size of the No Surprises Act, its delayed effective date, and the likelihood that significant regulatory guidance will appear later in 2021, we will address the No Surprises Act in detail as a separate Alert in 2021.
Limited Relief for Qualified Transportation Fringe Benefit Plans
The Act does not provide any relief for qualified transportation fringe benefit (“QTF”) plans. Existing IRS guidance does not permit employers to refund unused QTF plan contributions and there is no COVID relief guidance affecting this in any way.
The IRS informally indicated it approves of the following administrative relief if the QTF plan document allows it, or if the employer amends the QTF plan to allow it:
- Carryovers from an individual’s parking account to a transit account (or vice versa) for the following plan year; and
- Transfers from a parking account to a transit account (or vice versa) during a plan year in progress.
The monthly QTF plan reimbursement limits still apply. An employer administering this relief may consider being lenient on substantiation, particularly for older expenses.
[1] Run-out periods and grace periods do not count as part of the FSA plan year for this purpose.
[2] DCFSAs cannot use a carryover feature without this relief.
[3] This relief does not apply if the child is already 13 years old before the following DCFSA plan year begins.
[4] The Act’s other FSA relief sections expressly indicate the FSAs may allow the relief. This particular relief does not and merely refers to the increased age limit for the purposes of determining qualifying child care expenses that “may be paid or reimbursed.”
[5] We do not believe Congress intended this to conflict with FSA relief for plan years that ended earlier in 2020 and that retroactive application is still consistent administration in those instances.
The information contained herein is for general informational purposes only and does not constitute legal or tax advice regarding any specific situation. Any statements made are based solely on our experience as consultants. Marsh & McLennan Agency LLC shall have no obligation to update this publication and shall have no liability to you or any other party arising out of this publication or any matter contained herein. The information provided in this alert is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers or our clients. This is not legal advice. No client-lawyer relationship between you and our lawyers is or may be created by your use of this information. Rather, the content is intended as a general overview of the subject matter covered. This agency is not obligated to provide updates on the information presented herein. Those reading this alert are encouraged to seek direct counsel on legal questions. © 2020 Marsh & McLennan Agency LLC. All Rights Reserved.
You May Also Be Interested In
- Event
01.27.2021
Webinar | The New Norm: Maintaining Productivity While Working From Home
- Event
02.04.2021
Webcast | Continued Road to the Vaccine: Clinical and Compliance Considerations for Employers
- Event
02.18.2021
Webcast | HIPAA Privacy and Security Training
- Event
03.16.2021
Webinar | Pay Equity Disputes and Risks
- Event
03.18.2021
Webcast | How to Survive a U.S. Department of Labor Audit
- Event
04.15.2021
Webcast | Qualifying Life Events and Permitted Election Changes
- Event
05.20.2021
Webcast | Wellness Programs
- Event
06.17.2021
Webcast | Mid-Year Compliance Review
- Event
07.15.2021
Webcast | FMLA and Employee Benefits
- Event
08.19.2021
Webcast | Medical Expense Spending Accounts (Health FSA, HRA, HSA)
- Event
09.16.2021
Webcast | COBRA
- Event
10.21.2021
Webcast | Domestic Partner and Non-Tax Dependent Coverage
- Event
11.18.2021
Webcast | ACA Reporting Requirements
- Event
12.16.2021
Webcast | Year-End Compliance Review and Forecast
- Blog
01.25.2021
Summary of Benefits Provisions in the 2021 Consolidated Appropriations Act – Part 2
- Blog
01.22.2021
Annual CMS Medicare Part D Disclosure Due for Calendar-Year Plans
- Event
01.21.2021
Webcast | State Individual Mandate Reporting Requirements
- Blog
01.21.2021
A Bitter Pill to Swallow
- Event
01.20.2021
Webinar | New Developments in the Classification of Workers
- Event
01.13.2021
Webinar | Leave of Absence and Return to Work Issues in the Era of COVID-19
- Blog
12.29.2020
A Coronavirus Update for Employers
- Event
12.17.2020
Webinar | Year End Checklist 2020 and Future Forecast 2021
- Blog
12.04.2020
Additional Health Reimbursement Arrangements Allowed Under Final Rules
- Blog
11.20.2020
Federal Agencies Issue Final Rules Addressing Transparency in Coverage
- Event
11.19.2020
Webinar | ACA Reporting Requirements 2020
- Event
11.12.2020
Webcast | 2020 Election Results: The Impact to Benefit Plans
- Blog
10.30.2020
A Summary of 2021 Health and Welfare Plan Limits and Other Annual Adjustments
- Blog
10.22.2020
Final 2020 IRS Forms 1094/1095 Published
- Event
10.15.2020
Webinar | Health Savings Accounts 2020
- Blog
10.14.2020
INSIGHTS Newsletter
- Blog
10.09.2020
Michigan Revises No-Fault Auto Insurance
- Blog
10.09.2020
Affordable Care Act Reporting Relief Extended for 2020
- Event
10.08.2020
Webcast | A Tale of Two Breaches
- Blog
09.24.2020
DOL Issues New FFCRA Leave Guidance
- Event
09.17.2020
Webinar | FMLA and Employee Benefits 2020
- Blog
09.14.2020
Transportation Fringe Benefits Update
- Blog
08.31.2020
Massachusetts Family Medical Leave Update: Renewal of Fully Insured and Self-Funded Private Plan Exemptions, Upcoming Dates, Plan Options and Benefit Coordination
- Blog
08.26.2020
The Empire State Strikes Back
- Event
08.20.2020
Webinar | Compliance Considerations When Self-Insuring 2020
- Blog
07.29.2020
2021 Employer Affordability Safe Harbor
- Event
07.22.2020
WEBINAR | Next Chapter: Massachusetts Family Leave Act 2021
- Blog
07.22.2020
Massachusetts Paid Family Medical Leave Update (July 2020)
- Blog
07.22.2020
The Rise of State Individual Mandates - July 2020
- Blog
07.22.2020
Massachusetts Creditable Coverage – Employer Update (2020)
- Event
07.16.2020
Webinar | Annual Required Notices 2020
- Blog
07.01.2020
IRS Addresses Direct Primary Care and Health Care Sharing Ministries
- Blog
06.30.2020
Proposed ESG Regulation
- Event
06.18.2020
Webinar | Mid-Year Compliance Review 2020
- Blog
06.16.2020
COVID-19 Plan Administration Relief: The Good, the Bad, and the Ugly
- Blog
06.16.2020
What’s Old is New Again – Annual PCORI Fee is Due July 31st
- Event
05.28.2020
Webcast | COVID-19 Update: Navigating the Coronavirus, Vaccines, Testing and Wellbeing
- Blog
05.28.2020
DOL Finalizes Rule Expanding Use of Electronic Delivery for Plan Documents
- Blog
05.27.2020
2021 Plan Limits and Final Coupon Guidance Released
- Blog
05.27.2020
A Tale of Two IRS Notices
- Event
05.21.2020
Webinar | COBRA 2020
- Event
05.19.2020
Webinar | Legal and Compliance Return to the Workplace: Considerations for Employers
- Blog
05.11.2020
IRS and DOL Extend Filing Deadlines Due to COVID-19
- Blog
04.20.2020
IRS Extends Deadlines Due to COVID-19
- Event
04.16.2020
Webcast | COVID-19: Managing the Impact- Weekly Update 4.16.20
- Event
04.16.2020
Webinar | ERISA Basics 2020
- Blog
04.10.2020
CARES Act Signed Into Law
- Event
04.09.2020
Webcast | COVID-19: Managing the Impact- Weekly Update 4.9.20
- Event
04.02.2020
Webcast | Update on COVID-19: Navigating the Coronavirus and Managing the Impact
- Blog
03.30.2020
CARES Act Provisions Expand Retirement Plan Access for Individuals Impacted by COVID-19
- Blog
03.27.2020
FFCRA Employee Rights Poster Notification Poster Available
- Blog
03.26.2020
DOL Issues New Guidance on FFCRA and Required FFCRA Posters
- Event
03.24.2020
Webinar | Navigating the Coronavirus and Managing the Impact
- Blog
03.23.2020
The Rise of State Individual Mandates - March 2020
- Event
03.19.2020
Webinar | HIPAA Privacy and Security Training 2020
- Blog
03.10.2020
Federal Agencies Issue Proposed Rules Addressing Transparency in Coverage
- Event
02.20.2020
Webinar | Qualifying Life Events & Permitted Election Changes 2020
- Blog
02.13.2020
The Rise of State Individual Mandates
- Blog
02.10.2020
Annual CMS Medicare Part D Disclosure Due for Calendar-Year Plans
- Event
01.23.2020
Seminar | Employment Law Landscape 2020
- Blog
01.22.2020
The Affordable Care Act’s Employer Mandate: Part 4
- Event
01.16.2020
Webinar | Wellness Programs 2020
- Blog
12.26.2019
Repeal, Repeat, Remand – Ho Ho Hum?
- Event
12.19.2019
Webinar | Year End Checklist and Future Forecast
- Blog
12.09.2019
Employer HIRD Form Due on December 15, 2019
- Blog
12.04.2019
Affordable Care Act Reporting Relief Extended for 2019
- Event
11.21.2019
Webinar | ACA Reporting Requirements
- Blog
11.20.2019
IRS Releases Draft 2019 Instructions for Forms 1094/1095
- Blog
11.08.2019
IRS Releases 2020 Limits for FSAs and Other Benefits
- Blog
10.28.2019
California Mandates a Notice Requirement for Flexible Spending Accounts
- Blog
10.28.2019
All That Glitters is not Gold
- Blog
10.28.2019
The Affordable Care Act’s Employer Mandate: Part 3
- Blog
10.28.2019
Medical Loss Ratio Rebates
- Event
10.17.2019
Webinar | Health Savings Accounts
- Blog
10.09.2019
2019 Massachusetts HIRD Form Filing Deadline Approaches
- Blog
10.04.2019
Insurance Carriers Approved for Mass Paid Family Medical Leave Act
- Blog
09.30.2019
New Health Reimbursement Arrangements Allowed Under Final Rules
- Event
09.19.2019
Webinar | New HRA Options
- Blog
09.19.2019
2020 Employer Affordability Safe Harbor
- Blog
09.18.2019
The Affordable Care Act’s Employer Mandate: Part 2
- Blog
09.17.2019
Medicare Part D Notice Reminder
- Event
08.15.2019
Webinar | Association Health Plans
- Blog
08.12.2019
And in this Corner…the Fight to Expand Association Health Plans Continues
- Blog
07.31.2019
New Guidance on Mass FMLA Payroll Contributions and Wage Withholdings
- Blog
07.22.2019
IRS Expands Definition of Preventive Care for Qualified High Deductible Health Plans
- Event
07.18.2019
Webinar | Annual Required Notices 2019
- Blog
07.10.2019
Tax Consequences of Gym Membership Reimbursement
- Blog
07.09.2019
Agencies Release 2020 Adjusted Limits
- Blog
07.08.2019
The Affordable Care Act’s Employer Mandate: Part 1
- Blog
07.01.2019
President Signs Executive Order to Improve Healthcare Price and Quality Transparency
- Event
06.20.2019
Webinar | Mid-Year Compliance Review
- Blog
06.18.2019
Mass Paid Family Medical Leave Update
- Blog
05.28.2019
Potential FMLA Violations
- Blog
05.24.2019
Annual PCORI Fee is due
- Blog
05.23.2019
The Status of Qualified Transportation Fringe Benefits
- Event
05.16.2019
Webinar | Wellness Programs
- Blog
05.03.2019
Massachusetts Online Exemption Application Now Available for Employers Seeking a Private Plan Option to State Paid Family Medical Leave Program.
- Blog
04.30.2019
Massachusetts Employer Alert
- Blog
04.26.2019
Massachusetts Releases New Guidance and Employee Notice Template For Massachusetts Paid Family and Medical Leave (PFML)
- Event
04.18.2019
Webinar | HIPAA Privacy & Security Training
- Blog
04.11.2019
Leave Laws Continue to Multiply
- Blog
04.10.2019
Massachusetts Creditable Coverage
- Blog
04.02.2019
Association Health Plans (AHPs) – Update
- Blog
03.25.2019
U.S. Department of Labor Releases Proposed Overtime Rule
- Event
03.21.2019
Webinar | Federal Continuation Coverage
- Blog
03.19.2019
Deadline Approaching: Paid Family and Medical Leave Act
- Blog
03.06.2019
Reminder: Annual CMS Medicare Part D Disclosure
- Blog
03.05.2019
Mistaken HSA Contributions
- Blog
03.04.2019
Frequently Misunderstood Health Savings Account Issues
- Event
02.21.2019
Webinar | FMLA & Employee Benefits
- Event
02.13.2019
Seminar | How to Survive a DOL Audit
- Blog
02.05.2019
Government Considering Modifications to HIPAA Privacy and Security Rules
- Blog
02.04.2019
Automatic Enrollment Given a Boost
- Event
01.29.2019
Employment Law Landscape 2019
- Event
01.17.2019
Webinar: ACA Reporting Requirements
- Blog
12.31.2018
Slowly Filling in the Blanks
- Blog
12.27.2018
Women’s Contraceptive Coverage under the Affordable Care Act (ACA) – Update
- Blog
12.20.2018
Making a List and Checking It Twice
- Blog
12.18.2018
Texas Federal Court Rules ACA Unconstitutional
- Event
12.14.2018
Webinar | Q4 2018 Health Care Reform Update
- Blog
12.03.2018
An End to Pharmacy Gag Clauses
- Blog
12.03.2018
Employment Law Update: Minimum Wage Keeps Climbing
- Blog
11.29.2018
2018 Form 1094/1095 Reporting
- Blog
11.21.2018
Do the HIPAA Privacy and Security Rules Apply to My Organization? Part Two
- Event
11.20.2018
Webinar | Back to Basics: Consumer-Based Plans 101
- Blog
11.16.2018
Better Late Than Never
- Blog
11.02.2018
Compliance Update: HRAs Poised For a Facelift
- Blog
10.22.2018
FMLA Update - Organ Donation
- Blog
10.18.2018
Do the HIPAA Privacy and Security Rules Apply to My Organization?
- Blog
09.14.2018
Navigating the Wellness Program Rules for 2019
- Event
01.23.2018
Employment Law Landscape 2018
- Blog
10.06.2017
Interim Rules on Contraceptive Exemptions