Posts from September 2019.

Has your employee sought premium tax credits (PTCs) for coverage under a health insurance marketplace? If so, this could be an opportunity for you to reduce your ACA penalty risk. When an employer receives notice from a health insurance marketplace that an individual is eligible for PTCs, the best course of action is to read the notice carefully and ask plenty of questions: What is the deadline to appeal? Is this individual still an employee? Are you an applicable large employer under the ACA? Is the employee full-time or part-time?  Was affordable, minimum value coverage offered to ...

In our August Monthly Minute, we touched on the precarious future of drug accumulator programs in light of recently released guidance that appeared to significantly limit their application and usefulness from a cost-management perspective.  Some of those fears have just been put to rest – for the time being. On August 26, 2019, new guidance was released that acknowledged certain ambiguities about the treatment of drug manufacturer’s coupons in circumstances other than in which there is a medically appropriate generic equivalent available. Although the new ...

On September 19, 2019, the final regulations were published making 401(k) hardships easier for participants. Although there are no major departures from last year’s proposed regulations, plan administrators will want to be aware of several key updates, including –

  • The list of safe harbor expenses that are considered to satisfy the “immediate and heavy financial need” threshold has been expanded: the home casualty hardship reason is not limited by IRC 165(h)(5) and need not be in a federally declared disaster area, and expenses incurred as a result of certain federally ...



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