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Another Court Rules Against Cross-Plan Offsetting

… As a refresher from a previous article, generally, the Third-Party Administrator (TPA) or insurer of a medical plan may withhold payments to a provider on a new claim to recoup overpayments made to that same provider for other claims. This practice typically occurs in situations such as coordination of benefits, subrogation, or payment mistakes. In addition, cross-plan offsetting occurs when a TPA or insurer, with multiple employer clients, offsets payments to a particular provider for one client’s plan to recoup the overpayments made to that provider from another client’s plan or policy. The Employee Retirement Income …

https://www.epicbrokers.com/insights/another-court-rules-against-cross-plan-offsetting/

Federal Agencies Release New and Additional Guidance Related to COVID-19

Several Federal Agencies have issued COVID-19 (coronavirus) related guidance. On July 26, 2021, the Department of Health and Human Services (HHS) issued guidance addressing how nondiscrimination rules apply to the condition dubbed “long COVID.” On that same day, the Internal Revenue Service (IRS) released Notice 2021-46 to explain further the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium assistance available under the American Rescue Plan Act of 2021 (ARPA). On July 29, 2021, the IRS updated its Frequently Asked Questions (FAQs) on the paid sick and family leave tax credits available under ARPA to clarify the types of employee

https://www.epicbrokers.com/insights/federal-agencies-release-new-and-additional-guidance-related-to-covid-19/

Market Pulse Survey: COVID-19 Vaccine & Return to Office Plans

What is Your Company’s Approach to the COVID-19 Vaccine & Return to Office Plans? Earlier this year, we released a survey to determine employers’ initial thoughts on how the availability of the vaccine would be addressed in their workforce. At that time, very few companies were requiring inoculation. In light of the recent surge in the Delta Variant, more companies are now rethinking their approach. Forbes reported that several large tech companies are now going to be requiring vaccinations. Walmart also announced that their corporate staff would be required to be vaccinated and store/warehouse staffers would be incented …

https://www.epicbrokers.com/insights/market-pulse-survey-covid-19-vaccine-return-to-office-plans/

Getting Back to Business Travel While Facing the Delta Variant

Employers encounter an array of issues as employees return to offices and the world looks towards the future with an eye on COVID-19 and its ever-changing variants. Global benefits strategy and preparedness issues for American companies with locations outside the U.S. most likely keep their benefits managers and human resources teams up at night. On top of return-to-office challenges around the world, global travel is starting to increase – but with that comes many concerns. Viewpoints from Matt Marmorek Several of our clients have resumed business travel outside the U.S., and our number-one piece …

https://www.epicbrokers.com/insights/getting-back-to-business-travel-while-facing-the-delta-variant/

Maryland Public Health Emergency Paid Sick Leave

Maryland is the latest state to implement a paid sick leave law, H.B. 581, the Maryland Essential Workers’ Protection Act (the Act). Maryland’s law provides paid leave to employees working in Maryland who are unable to work due to a public health emergency related to a communicable disease. The new law became effective on June 1, 2021, but the paid leave provisions are on hold until the state government provides funding. On May 28, 2021, Maryland Governor Larry Hogan announced his intention to allow the Act, to become law without his signature. The Act requires essential employers to …

https://www.epicbrokers.com/insights/maryland-public-health-emergency-paid-sick-leave/

Departments Provide Long-Awaited Guidance on the No Surprises Act

… ensuring compliance with these new rules; however, self-funded plan sponsors are legally responsible for ensuring compliance. The guidance does not address all the provisions of the No Surprises Act including but not limited to guidance on the independent dispute resolution process, the good faith estimates and advanced explanation of benefits, provider directories or continuity of care. Background On July 1, 2021, The Office of Personnel Management (OPM), along with the departments of Health and Human Services (HHS), Labor (DOL), and Treasury released “Part 1” of regulations implementing the No Surprises Act. The interim final rule with comment period (IFC …

https://www.epicbrokers.com/insights/departments-provide-long-awaited-guidance-on-the-no-surprises-act/

IRS Releases Additional COBRA Subsidy FAQs

Quick Facts On July 26, 2021, the IRS released additional FAQs on the ARPA COBRA subsidies. The Notice includes clarifying guidance on dental and vision only coverage, state continuation coverage and entities that may claim the premium tax credit. COBRA subsidies are available for certain COBRA qualified beneficiaries from April 1, 2021, through September 30, 2021. Overview The Internal Revenue Service (IRS) has issued new COBRA subsidy guidance in Notice 2021-46 (the Notice) through a set of frequently asked questions (FAQs) which supplements guidance released earlier in Notice 2021-31 regarding COBRA premium assistance under the American Rescue Plan …

https://www.epicbrokers.com/insights/irs-releases-additional-cobra-subsidy-faqs/

IRS Releases Updated Form 941 for ARPA Premium Tax Credits

Quick Facts Employers who offer group health plan coverage subject to federal COBRA and have AEIs who elect to take advantage of the COBRA subsidy may be able to claim a credit against the Medicare portion of their payroll The credit will generally be claimed using IRS Form 941. Employers will need to report the dollar amount of the COBRA subsidies as well as a count of the number of individuals who were provided the COBRA subsidy. Background Form 941, the employer’s quarterly federal tax return, has been updated to allow employers to claim a credit for any Consolidated …

https://www.epicbrokers.com/insights/irs-releases-updated-form-941-for-arpa-premium-tax-credits/