Key Benefits Issues During Current Pandemic Ma rc h 2 5 , 20 20 Cl - - PowerPoint PPT Presentation

key benefits issues during current pandemic
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Key Benefits Issues During Current Pandemic Ma rc h 2 5 , 20 20 Cl - - PowerPoint PPT Presentation

Key Benefits Issues During Current Pandemic Ma rc h 2 5 , 20 20 Cl ien t W eb ina r B R I A N M O R R I S , P r e s i d e n t J A S O N C O G D I L L , B e n e f i t s A t t o r n e y This Session Update on developments in Congress


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SLIDE 1

Key Benefits Issues During Current Pandemic

Ma rc h 2 5 , 20 20 Cl ien t W eb ina r

B R I A N M O R R I S , P r e s i d e n t J A S O N C O G D I L L , B e n e f i t s A t t o r n e y

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SLIDE 2

This Session

  • Update on developments in Congress
  • Discussion of common Qs & key issues
  • Your questions
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SLIDE 3

Update: New Stimulus Package

  • Not yet finalized by Congress or signed by President
  • Expected to include a number of relief provisions for

individuals & businesses

  • Practical example: OTC medications for FSAs, HRAs,

HSAs

  • Repeal of ACA rule; fully allowed without Rx
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SLIDE 4

Update: Families First COVID-19 Response Act

  • Part 1: Emergency Paid Sick Leave Act
  • Effective 4/2/20
  • Applies to employers with fewer than 500 EEs
  • Exception for certain health care providers or first responders
  • Provides up to 80 hrs (FT) or equivalency (PT) for EEs unable

to work because of 6 specific COVID-19 related reasons

  • Caps on available amounts; funded by ER tax credit
  • Additional guidance coming from DOL
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SLIDE 5

Update: Families First COVID-19 Response Act

  • Part 2: Paid FMLA
  • Effective 4/2/20
  • Applies to employers with fewer than 500 EEs
  • Applies to EEs who have worked 30 days or more
  • Exception for certain health care providers or first responders
  • Designed to assist EEs with school & child care related

COVID-19 issues if EE cannot work or telework

  • Caps on available amounts; funded by ER tax credit
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SLIDE 6

Update: Families First COVID-19 Response Act

  • Additional provisions
  • Group medical plans must cover COVID-19 testing &

treatment

  • Coverage of COVID-19 testing & treatment (& now

telemedicine option without copay) will not impact HSA bank account eligibility for HDHP participants

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SLIDE 7

Key Issue #1: Current Benefit Elections

  • In effect until there is a change in eligibility or
  • ther qualifying event
  • Difference in elections paid pre-tax vs. post-tax
  • No specific relief announced by IRS for Section

125 plans

  • No recognized QEs for reduction of hours or

reduction in pay not affecting eligibility

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SLIDE 8

Key Issue #2: Eligibility Scenarios

  • Active status
  • Termination of employment
  • Leave of absence (paid or unpaid)
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SLIDE 9

Eligibility: Best Practices

  • Know what the document (plan SPD) states for each

individual benefit

  • Ensure that eligibility is administered consistently

with SPD

  • For health insurance, consider ACA requirements
  • Consider any carrier contract provisions
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SLIDE 10

Active Status

  • No change in eligibility unless reduction of hours
  • Employer may elect to maintain status quo
  • Employer may elect to modify benefits offered
  • Employer may elect to change contributions

(which could trigger QE)

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SLIDE 11

Leaves of Absence

  • Two initial questions:
  • Paid or unpaid
  • FMLA or non-FMLA
  • Assess leave policy, if applicable
  • Communicate clearly with EE regarding leave details

– employment status & how benefits to be handled

  • Employer has options regarding how to handle

premium payments & collection

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SLIDE 12

Leaves of Absence (cont.)

  • For unpaid leaves subject to FMLA (or employer

policy), standard period is 12 weeks

  • Be prepared to terminate coverage timely if EE does

not return to work per plan provisions

  • Note: Separate training webinar available on topic
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SLIDE 13

Termination of Coverage: Best Practices

  • Know what the document states for each individual

benefit (plan SPDs)

  • Ensure that termination of coverage is administered

consistently with document

  • *** Consider any carrier contract provisions (fully

insured plans) or administrative agreement provision (self-funded plans) ***

  • Applicable Large Employers (ACA): Don’t forget

stability period requirement for group medical

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SLIDE 14

COBRA

  • COBRA applies to all “group health plans”
  • If benefit is COBRA eligible, & if one of 7 triggering

events applies, COBRA must be offered within 44 days (Election Notice)

  • COBRA applies for up to 18 months unless special

extension applies (disability; multiple qualifying events)

  • *** Employer has options on assisting with

premium cost

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SLIDE 15

State Continuation

  • Applies to employers not subject to COBRA
  • Generally applicable only to group medical insurance
  • South Carolina: Employee must have been employed

and enrolled for at least 6 months; maximum coverage period 6 months

  • *** Employer has options on assisting with premium

cost

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Use Question box on control panel - open & expand to see all replies

You may submit Qs via Control Panel (“Questions”) now, or you may submit via email to your Fulcrum Risk Solutions contact at your convenience