Health Care Legislation Drives HSA Adoption

Health care legislation drives HSA adoption | BenefitsPRO

Source: BenefitsPRO, by Shobin Uralil

The IRS isn’t the most nimble of organizations, and it would be a stretch to say that health benefits organizations savor oversight. However, what we have seen recently from the IRS (and Congress) is a dedicated and purposeful movement to expand health savings options. In direct response to ‘unprecedented times,’ they have methodically increased health plan flexibility and contribution amounts for related tax-free savings options.

The steady rollout of IRS notices and relief packages that include health care coverage or contribution expansion has increased flexibility for all eligible Americans. It’s a speed of change that providers and account holders have never before witnessed. The resulting impact is an immediate increase in flexibility. The longer-term impacts will likely shift health plan design and selection, if the legislative changes resulting from relief packages become permanent changes. Employer education is also required to keep up with the speed of change so employees can understand the impact of those changes.

Legislative review

Recent legislative changes are making Health Savings Accounts (HSAs) and Flexible Spending Accounts (FSAs) even more attractive for Americans.

The CARES Act –  On March 27th, 2020, Congress passed and the President signed the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act). The CARES Act has expanded HSA-eligible items to include over-the-counter (OTC) medical products without a prescription, or letter of medical necessity from a physician. This includes previously ineligible items like allergy medication, cough medication, and pain relievers, along with menstrual care and other feminine hygiene products. The change applies to all qualified purchases made after January 1, 2020.

At the same time, “telemedicine,” or “telehealth” is now  temporarily HSA-eligible. This is effective for any appointments or services covered under HSA-eligible health plans that begin between March 27, 2020, and December 31, 2021.

During this time, an HSA-qualified plan that covers any portion of telehealth and/or remote care services before the deductible will not lose their HSA eligibility because of the telehealth coverage. To the extent that telehealth and/or remote care services cost anything, they can be paid for using HSA dollars for approximately the next two years. It remains to be seen if this new category becomes permanent.

Consolidated Appropriations Act of 2021 – This is directed entirely at FSA plan eligibility and coverage and applied at the discretion of each plan sponsor.

  • * Employers can offer FULL CARRYOVER of unused funds, with no penalty,  of all 2020 FSAs (Health, Limited Purpose, and Dependent Care) in 2021
  • * FSAs may permit a 12-month grace period, with no penalty.
  • * A Medical FSA participant terminating participation during a plan year may spend down unused funds for the remainder of the plan year, if the plan permits, for any plan year ending in 2020 or 2021.
  • * If a Dependent Care FSA’s plan year enrollment was prior to January 31, 2020 and a participant’s qualifying dependent turned 13 during such plan year, the participant is eligible to enroll in and use Dependent Care FSA for the subsequent plan year to cover such dependent.
  • * A Plan may permit participants to change elections in the Plan Year ending in 2021 without experiencing a qualifying life event.

These are not requirements for plan providers or employers, but rather new options.

American Rescue Plan Act of 2021 – Dependent Care FSA contribution limits DOUBLE! This temporarily increases the tax-free Dependent Care FSA reimbursable limit to $10,500 ($5,250 for married couples filing separate tax returns) in the taxable years beginning after December 31, 2020, and before January 1, 2022. This relief is an option and employers are not obligated to adopt the increase in contribution.

The Emergency Relief Act – Due to the recent winter storm, which greatly impacted the state of Texas and Oklahoma, the IRS issued TX-2021-02, OK-2021-01, and LA-2021-01 allowing Texas, Oklahoma, and Lousinna citizens to contribute to their HSAs until June 15, 2021. All individuals who reside in Texas, Oklahoma or Lousianna are eligible for this relief.

On top of that, for the second year in a row, in response to the ongoing coronavirus pandemic, the federal income tax filing deadline and HSA contribution deadline have been postponed to May 17, 2021.

The result is more time to contribute for existing account holders. Note that each state has its own filing deadline. Account holders who want to make a new or extra 2020 HSA contribution should file according to their 2020 state tax filing deadline.

What you are seeing is an unprecedented movement to increase flexibility of tax-advantaged HSA and FSA accounts, increased contributions amounts (for DCFSA accounts), and more time for all existing account holders to contribute to their HSA. If made permanent,  the culmination of these changes will shape health care enrollment for years to come.

2021 HSA contribution amounts

For 2021, HSA-eligible account holders are allowed to contribute $3,600 for individual coverage and $7,200 for family coverage. Both coverage levels are a $50 increase for individuals and $100 for families from 2020 HSA contribution limits.

If you are 55 years or older, you’re still eligible to contribute an extra $1,000 catch-up contribution.

The legislation outlined above had no expected impact on 2021 HSA contribution limits or the 2021 federal tax deadline. This only applies to 2020 HSA contributions (filing timing, not limits) as they relate to the federal tax deadline.

2021 FSA contribution amounts

Health FSA Contribution Limit  – Whether they’re an individual or a member of a family, an employee’s contributions combined with their employer’s cannot exceed $2,750 in 2021.

Dependent Care FSA Contribution Limit – In 2021, employees may contribute up to $5,000 if they file taxes as an individual, or are married and filing taxes jointly. They may contribute up to $2,500 if they’re married but filing taxes separately (each spouse can contribute $2,500 to separate FSAs). As noted above, based on the American Rescue Plan Act of 2021, DCFSA contribution limits have increased to $10,500 ($5,250 for married couples filing separate tax returns) in the taxable years beginning after December 31, 2020, and before January 1, 2022.

Limited Purpose FSA Contribution Limits – In 2021, the total contribution amount for a Limited Purpose FSA cannot total more than $2,750. This includes contributions made both from an employer and an employee.

Will history repeat itself?

HDHPs surged after the 2009 recession. After the 2009 recession, HSA assets increased from $7.2 billion in 2009 to $12.2 billion in 2011, according to Devenir.

The pandemic, resulting legislative changes, and increased awareness of the benefits of HSAs will lead to an even greater surge of employers turning to HSA-eligible HDHPs as a way to increase savings and offer more diversified health care options that cater to individuals looking to balance short-term and long-term upsides.

The last year has illuminated the employee’s desire and need for robust health and financial wellness benefits, and it’s more clear than ever that the HSA is one of the only benefits that checks both of those boxes.

Even though it’s hard to imagine the IRS and Congress working in partnership to expand health care coverage and tax-free contributions, the resulting impacts are cohesive in effect. The requirement for providers, consultants, brokers and employers alike is to ensure employers are readily aware of the new regulations and how they impact health plan usage and selection.

COVID-19 pushed the American health care system to its breaking point. It could also be the beginning of a movement to increase healthcare affordability and coverage. Iterative change feels like a drop in the bucket, but the combination of these new changes will accelerate current trends and with some continued support, expansion of tax-advantaged health savings to all Americans.

3 Major Health Items Included In Biden’s Budget Request

3 major health items included in Biden's budget request | FierceHealthcare

Source: Fierce Healthcare, by Robert King

President Joe Biden proposed an ambitious budget for the next federal fiscal year that includes more money for fighting the opioid epidemic, bolstering public health and several other healthcare items.

The budget request to Congress, released Friday, acts as essentially a wish list of priorities for the administration for the next year.

It is doubtful how much would get approved by Congress but sends a message of what the administration prioritizes.

Here are three healthcare priorities outlined in the request:

  • * The opioid epidemic: $10.7 billion was requested for fighting the opioid epidemic, $3.9 billion over the 2021 enacted level. The money will help support research, prevention and recovery services. The administration also is calling for targeted investments for “populations with unique needs, including Native Americans, older Americans and rural populations,” according to a release from the Office of Management and Budget on Friday.
  • * Public health infrastructure: $8.7 billion was requested for the Centers for Disease Control and Prevention to boost public health capacity in states and territories. OMB calls the budget increase the largest in nearly two decades for the agency at the frontlines of combating COVID-19. The Biden administration hopes to use the new money to train new epidemiologists and public health experts and “build international capacity to detect, prepare for and respond to emerging global threats.” A letter sent Friday to congressional leaders from the White House said that CDC funding was 10% lower than the previous decade after adjusting for inflation.
  • * Research funding boosts: $6.5 billion to launch a new agency called the Advanced Research Projects Agency for Health. The new agency would provide major increases in federal research and development spending on cancer and other diseases such as diabetes and Alzheimer’s. The goal of the investment is to “drive transformational innovation in health research and speed application and implementation of health breakthroughs,” OMB’s letter to Congress said. The funding is rolled into a $51 billion request for funding to the National Institutes of Health.

Healthcare Reform Sees Growing Support From Employers

Healthcare reform sees growing support from employers | Employee Benefit  NewsSource: Employee Benefit Adviser, by Amanda Schiavo

As businesses look to get back to normal in a post-pandemic world, they’re eager to make changes to help them better support and deliver healthcare to their employees.

Employer support for healthcare reforms is growing, according to data from the National Alliance of Healthcare Purchaser Coalitions. Indeed, 87% of employers surveyed find drug price regulation helpful and 79% of employers want more regulation related to surprise billing. Furthermore, 75% of employers are in favor of hospital price transparency, while 75% want hospital rate regulation.

“While employers are very focused on a successful vaccination effort for their people right now, they are also taking a more strategic look at their health and benefits strategies going forward,” says Michael Thompson, president and CEO of the National Alliance. “Plans are shaping up now for employers to improve health, equity and healthcare value over the next few years.”

Employers are anticipating a return to work by the third quarter of the year, but those plans may be dependent on workplace vaccination rates, according to the survey. However, employers are cautious about mandating a vaccine for employees. Only 8% of employers anticipate mandating the vaccine for employees, the survey found.

Nearly one in three Americans still have no plans to get a COVID vaccine, according to the Associated Press-NORC Center for Public Affairs Research. To combat fear and misinformation, 81% of employers say they are providing information to employees about the benefits of getting inoculated. Seventy-six percent of employees are offering education for employees about their eligibility, 69% on safety and efficacy and 67% on how to access vaccines. Over 80% of large employers anticipate providing onsite COVID-19 vaccines before the year is over.

“Employers recognize that they are among the most trusted sources of information for the general public around coronavirus and vaccines in particular,” says Dr. Dena Bravata, chief medical officer at Castlight Health, a healthcare solutions provider. “Many employers have a history of providing influenza vaccines on site. Now they are thinking about how [they can] do something similar for COVID vaccinations, whether by bringing it on site, or using the same mechanisms to help educate their population around the importance of safety and efficacy.”

COVID: Nearly Half of California Adults Have Received a Vaccine Shot

COVID: Nearly half of California adults have received a vaccine shotSource: The Mercury News, by Leonardo Castaneda

Nearly half of Californians 18 and older have received at least one COVID-19 vaccine shot, an encouraging metric as some experts watch with concern spiking case rates in Michigan, New Jersey and elsewhere in the country.

So far, 46.8 percent of adults in California have received at least one vaccine shot, and 25.5 percent have been fully vaccinated, according to data from the Centers for Disease Control and Prevention. Among residents 65 and older, 81.5 percent have received at least one shot, and 57.4 percent are fully vaccinated.

The state has now administered 22 million doses, about 80 percent of those delivered to California, and is averaging 371,510 daily injections, an 11 percent increase from a week ago. On Thursday, California will expand eligibility to anyone 16 and older, although the state is also anticipating a significant decline in new doses from the federal government in the coming week, including an 88 percent decline in doses from the one-and-done Johnson & Johnson vaccine.

Meanwhile, case rates have remained steady, with counties reporting 3,545 new cases Friday for a seven-day average of 2,580 daily cases, according to data tracked by this news organization. Los Angeles County, the largest and hardest hit in the state, reported 712 new COVID-19 cases, followed by Sacramento County with 400 and Kern County with 260. They were followed by Santa Clara, San Diego and San Bernardino counties.

Hospitalizations from the deadly virus have also continued to decline in the state. As of Thursday, there were 1,930 patients hospitalized with confirmed cases of COVID-19, a 1.5 percent decline from the preceding day. That is the fewest number of confirmed hospitalized cases since at least April 8, 2020.

There were also 475 patients in intensive care unit beds with confirmed COVID-19 cases, a 3.3 percent decline from the preceding day and the lowest number of confirmed cases in ICU beds since at least March 29, 2020, the earliest data available.

Counties also reported 179 new deaths from the virus, for a seven-day average of 101 fatalities. That’s the lowest the average has been since Dec. 6, before a massive surge in cases and deaths over the winter and holidays. Los Angeles County reported 43 fatalities, followed by Riverside County with 27 and San Bernardino County with 24. They were followed by Santa Clara, Orange and San Diego counties.In the Bay Area, Santa Clara County reported 256 new COVID-19 cases and 23 deaths, for a total of 115,825 cases and 1,995 fatalities since the start of the pandemic. Contra Costa County reported 151 cases and two deaths for a total of 66,118 cases and 764 deaths. San Mateo County reported 46 cases and three deaths, for a total of 40,754 cases and 556 deaths.

San Francisco reported 20 cases and six deaths for a total of 35,425 cases and 493 deaths. Alameda County did not report new case or death data on Friday and has had 84,075 cases and 1,438 deaths since the start of the pandemic.

Employers: The American Rescue Plan Could Increase Your Risk of ACA Non-Compliance

Employers: The American Rescue Plan could increase your risk of ACA non- compliance | BenefitsPRO

Source: BenefitsPRO, by Kyle J. Scott

The American Rescue Plan, now federal law, is resulting in some of the biggest changes to the Affordable Care Act (ACA) since the ACA’s passage more than a decade ago. The new $1.9 trillion stimulus package supports healthcare affordability and increases marketplace access for millions of Americans by expanding consumer eligibility for premium tax credits to pay for health insurance premiums.

The American Rescue Plan also presents new implications for employers – and they’re not all positive. That’s because the new law contains provisions that can increase complexity and place employers at greater risk of incurring IRS penalties for ACA non-compliance.

New risks for employers

Under the ACA, employers are deemed at risk of incurring a fine (known as Penalty B) when they fail, for whatever reason, to offer affordable health coverage that meets minimum value requirements to eligible employees. Coverage is considered affordable if the employee’s contribution for employee-only (or single) coverage is less than or equal to 9.83% of their income. Failure to meet this requirement results in a $4,060 penalty per full-time employee who receives a premium tax credit (also called a subsidy) when purchasing insurance through a public healthcare exchange.

Until now, only individuals who made less than 400% of the federal poverty level (FPL) were eligible to receive a subsidy. Now, the American Rescue Plan expands eligibility by eliminating the 400% FPL income cap for tax years 2021 and 2022. With the threshold removed, more individuals will qualify for subsidies, resulting in greater risk to employers in failing to offer affordable coverage and potentially more work in responding to IRS requests.

When a full-time employee receives a marketplace subsidy, the IRS will send the employer a 226-J Letter with a notice of proposed Penalty B fines for each employee identified. For employers that do not meet the offer requirements, this could result in tens- or hundreds of thousands of dollars in fines. Even for compliant employers, responding to a 226-J Letter can be timely and costly.

On top of the new law, the pandemic-induced reduction of workforce hours already presents increased risk of employers’ plans being classified as unaffordable. Coverage for employees whose work hours and income have been reduced may no longer be considered affordable under the ACA. Affected employee(s) buying insurance through an exchange could set up a scenario in which the employer incurs an IRS 226-J penalty notice.

Affordability is a matter of perspective

Adding to the confusion for employers is that “affordability” is calculated differently on the exchanges than it is at the employer level.

Employers, following the rules set out for them under the ACA, can leverage safe harbors – the FPL, rate of pay or W2 calculations – to determine whether the coverage they offer each full-time employee is affordable. If affordability safe harbors is a new term for you, here’s how the IRS explains it:

“Employer-provided coverage is considered affordable for an employee if the employee-required contribution is no more than 9.78 percent (as adjusted) of that employee’s household income. In general, the employee required contribution is the employee’s cost of enrolling in the least expensive coverage offered by the employer that provides minimum value. The employee-required contribution includes amounts paid through salary reduction or otherwise and takes into account the effects of employer arrangements such as health reimbursement arrangements (HRAs), wellness incentives, flex credits, and opt-out payments.”

Employers may use a safe harbor to ensure the employee-required contribution is no more than the affordability threshold for a given year. You can even choose different safe harbors for different employee populations, in accordance with ACA guidelines.

Safe harbors were established because, as the law is written, the ACA determines affordability based on a taxpayer’s total household income – information that employers frequently don’t have access to. Exchanges, on the other hand, determine affordability on household size and household income – data they collect directly from the individuals who are applying for coverage.

What all this means is that there may be a larger subsidy-eligible population than an employer realizes within their workforce, especially for single earner households with larger families.

Advice for employers

With subsidies now available to a broader population, coupled with the pandemic-induced workforce impact, employers must be even more diligent in their ACA data collection and recordkeeping in case they need to defend themselves against Penalty B charges from the IRS if the premium on their lowest cost plan offering exceeds affordability requirements. The following steps can help employers avoid triggering a 226-J notice:

Validate your data by looking for anomalies Inconsistent data reflecting hire dates, offers of coverage, leaves of absence and disability classifications can all pose potential problems. Solidify your data and ensure accuracy.

Review and confirm the affordability of your safe harbor Consider the affordability of premiums for your lowest-paid employees, not just your average employee. Determine if your plans meet the FPL safe harbor. If it doesn’t, consider whether the Rate of Pay or W-2 safe harbor is a better fit. Work with your ACA technology solution to model affordability determinations.

Make the most of your eligibility determination solution Use your ACA technology solution to validate your total number of employees, their full-time status through monthly or look-back measurement, and your Form 1095-C code determination combinations, and potential fail codes and fail code combinations.

Closely examine your anticipated future premium costs Make sure you are making affordable offers to eligible employees and fully understand your risk profile. Remember that even your lowest premium plan might not be considered affordable under the ACA for employees whose work hours and income were reduced (because of the pandemic or for other reasons).

Promptly respond to any 226-J Letter you receive Whether an employer agrees or disagrees with a penalty assessment, they should contact their ACA reporting solution provider, or whomever assisted in generating their forms, immediately for assistance.

If you disagree with the assessment, first review your Form 1094-C and compare the Forms 1095-C for each identified employee to Form 14765, the Employee Premium Tax Credit Listing (you do not need to re-submit corrected Forms 1094-C or 1095-C).

Next, complete, date and sign Form 14764, “ESRP Response” and send it back to the IRS with any supporting documents by the due date written on the letter, with a statement describing why you are disputing the assessment. If you agree with the assessment, simply enclose a check for the amount requested and the process ends.

Once Form 14764 is sent, the IRS will acknowledge the employer’s response to Letter 226-J with Letter 227 which describes what action the employer must take, if any. After responding to Letter 227, or after your conference with the IRS Office of Appeals, you will receive Notice CP 220-J asking you to pay the reassessed penalty. If the numbers are correct and you have yet to pay the penalties, pay the amount requested electronically, or via check. If you continue to disagree with the assessment, consult legal counsel on how to proceed.

Other impacts of the American Rescue Plan for employers and ACA compliance The American Rescue Plan Act also provides for fully subsidized COBRA premiums from April 1 to September 30, 2021. During this five-month time frame, the Act reduces an employee’s COBRA premium to zero in anticipation of a tax credit and reduces an employer’s ACA Penalty B risk.

To illustrate: Amidst the pandemic and associated economic implications, it’s been common for employers to reduce an employee’s hours to contain costs. Because the employee is now earning less income, the employer’s offer of a COBRA plan is too expensive for the employee. Instead, the employee purchases coverage on the exchange, where they receive a subsidy. The subsidy then triggers a 226-J Letter to the employer. Under the ACA, the employer-offered COBRA coverage is deemed unaffordable to the employee. The employer is assessed a fine.

Now, under the American Rescue Plan Act, because the employee’s cost for COBRA is zero, the COBRA coverage offer is considered affordable, and the employer is not at risk for Penalty B.

A final word

Staying up to date on ACA employer responsibilities can be challenging. If you’re puzzling over how to avoid inadvertent non-compliance and associated financial penalties, be sure to turn to a trusted health reform technology partner that monitors the changing landscape and provides expertise on how to manage it.

American Rescue Plan Act: 9 Employer, Employee, And Health Care Provider Provisions

American Rescue Plan Act: 9 Employer, Employee, and Health Care Provider  Provisions | Word & BrownSource: Word & Brown, by Alex Strautman

The American Rescue Plan (ARP) Act, the latest COVID-19 relief measure put forth by the Biden administration, was signed into law in March 2021. It includes a variety of changes affecting the health insurance industry, business owners and managers, and health care providers.

Below is a summary of nine provisions in the ARP affecting employers, employees, and health care providers.


Federally Subsidized COBRA Premiums

The ARP provides a temporary 100% subsidy of COBRA premiums for the period of April 1, 2021, through September 30, 2021, for “assistance-eligible individuals (AEIs).” This includes employees involuntarily terminated or who involuntarily experienced a reduction in hours, resulting in a loss of benefit eligibility. The subsidy also extends to covered dependents of employees. Employers are expected to forward COBRA premiums, which will be later reimbursed by the IRS via quarterly payroll tax credits.

Paycheck Protection Program (PPP) Updates

An additional $7.25 billion is allocated in the ARP for the Paycheck Protection Program (PPP), created in 2020 to help small businesses deal with the economic fallout of COVID-19. One day before the PPP application deadline of March 31, 2021, President Biden extended the timeline for applying to May 31, with loan funding by the Small Business Administration (SBA) extended through June 30, 2021.

Under the PPP, qualifying small businesses can apply for a First Draw or Second Draw loan, with full loan forgiveness available if 60% of loan proceeds go toward payroll and other eligible expenses. In addition, under the ARP, eligibility for a PPP loan is extended to include non-profit entities, Internet-only news publishing organizations, and veterans’ organizations, subject to specified staffing and other limits.

Available Temporary Dependent Care FSA Maximum Contribution Increase

A temporary increase in the contribution maximum for a dependent care Flexible Spending Account (DCAP FSA) is also included in the ARP. The ceiling can now be $10,500 (up from $5,000) or $5,250 (up from $2,500) for married taxpayers filing separately for the 2021 tax year. This is a non-mandatory change, which allows employers to determine if they will permit the higher limits. Employers with DCAP plans that renewed 1/1/21, 2/1/21, or 3/1/21 that elect to allow the higher ceiling will want to hold a special enrollment in 2021 to give employees the opportunity to change their previous election for the year if Open Enrollment for the DCAP has already taken place. Other options include expanded carryover options or an extended 12-month grace period.

EIDL Advance

The Emergency Injury Disaster Loan (EIDL) program established as part of prior COVID relief assistance through the SBA gets a boost in the ARP. Businesses in low-income communities that previously did not receive an EIDL could now be eligible for a grant of up to $10,000, if the business has 300 or fewer employees and experienced a greater than 30% reduction in revenue. An additional $5,000 payment is available to a new tier of hard-hit smaller businesses – those with fewer than 10 employees with a reduction in revenue of greater than 50%.

Restaurant Revitalization Grants

ARP includes $28.6 billion for qualifying restaurants or food and drink service locations impacted by COVID-19 between February 15, 2020, and December 31, 2021. This includes $5 billion for eligible entities with gross receipts of less than $500,000 during 2019, and $23 billion for eligible entities of different sizes based on annual gross receipts. The SBA may adjust distribution of funds as necessary based on demand and the costs in the markets in which eligible entities operate.

Eligible businesses include the following:

  • * restaurants
  • * food stands
  • * food trucks
  • * food carts
  • * saloons
  • * inns
  • * taverns
  • * bars
  • * lounges
  • * brewpubs
  • * tasting rooms
  • * taprooms
  • * caterers

Tax Reporting for Gig Workers

Beginning in the 2022 tax year, more reporting is required by gig economy businesses (like Uber, Lyft, Thumbtack, and others) concerning their workers earning $600 or more annually. The threshold for using Form 1099-K is $20,000 currently. The change is expected to result in better income tax reporting and collection of tax payments from workers in this segment of the economy.

FFCRA Leave Extension and Expansion

As part of the Families First Coronavirus Response Act (FFCRA), beginning in January 2021, private sector employers with fewer than 500 employees were no longer required to provide emergency paid sick leave or family and medical leave – although they do have the option to provide leave and apply for refundable tax credits to offset related costs. (Employers can claim tax credits through September 30, 2021.)

If employees took 10 days of emergency paid sick leave under the FFCRA, the ARP allows an employer to provide those employees with an additional 10 days of leave, starting April 1, 2021. Employers can also claim a credit if they provide paid time off for employees to obtain the COVID-19 vaccination.

[Under California Senate Bill (S.B.) 95, the California Labor Code requires employers with more than 25 employers to provide up to 80 hours of COVID-19 supplemental paid sick leave to employees who are unable to work or telework due to related reasons. For additional information on SB 95, please refer to the National Law Review article, California Expands and Resets COVID-19 Paid Sick Leave, published on March 29, 2021.]


Federally Subsidized COBRA Premiums

As mentioned above, the ARP requires employers to forward 100% of COBRA premiums of assistance-eligible individuals (AEIs) between April 1, 2021, and September 30, 2021, which will later be reimbursed by IRS. Individuals qualify if they are entitled to COBRA at any time during the specified period – if they elect coverage, fail to elect coverage, or timely elect COBRA but drop it prior to April 1, 2021. For individuals who are eligible but failed to elect coverage (or let coverage lapse), the ARP mandates employers provide a new 60-day notice of the premium subsidy and the opportunity to enroll. The subsidy could end earlier than September 30, 2021, if the individual reaches the end of their 18-month maximum coverage period or becomes eligible for other group health coverage or Medicare. (Word & Brown published another ARP column last month by Director of Education and Market Development Paul Roberts; you can link to it in our Newsroom here.)

Marketplace Subsidy Eligibility

For 2021 and 2022, the ARP increases the availability of premium tax credits (PTCs) for individual and family coverage purchased through health insurance exchange marketplaces (such as Covered California and Nevada Health Link).

Federal PTCs are available to individuals earning between 100% and 400% of the Federal Poverty Level (FPL), based on a sliding scale. Those earning between 100% and 150% of FPL can get full coverage of their premiums paid for by PTCs. Those with incomes above 400% of FPL are eligible for assistance when their individual premium exceeds 8.5% of their overall household income. Individuals receiving unemployment benefits are also eligible for a $0 premium for coverage through a marketplace exchange.

FFCRA Leave Extension and Expansion

As mentioned previously, as part of the FFCRA, private sector employers with fewer than 500 employees are no longer required to provide emergency paid sick leave or family and medical leave for employees; however, they do have the option to provide such leave. If employees took 10 days of emergency paid sick leave under the FFCRA in 2020, the ARP allows an employer to provide those employees with an additional 10 days of leave, starting April 1, 2021.


COVID-19 Vaccine Distribution

Like other measures passed by Congress in the past year (such as the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and Families First Coronavirus Response Act (FFCRA), the ARP includes funding for vaccine testing, contact tracing, promotion, distribution, administration, and monitoring by the Centers for Disease Control and Prevention. It also supports workforce initiatives by state, local, and territorial public health departments to hire staff and secure equipment, technology, and other supplies. In total, more than $70 billion is allocated to public health funding projects, including $3 billion for block grants to address mental health and substance use disorders as well as behavioral health services.


For additional information on the ARP, read the American Hospital Association’s article, Summary of America Rescue Plan Act of 2021 and Provisions Affecting Hospitals and Health Systems, the National Law Review article, American Rescue Plan At of 2021: Key Healthcare Provisions, or Congress Passes ARPA With Many COVID-19 Payroll-Related Provisions, published by Thomson Reuters.

NOTE: This article is not intended to provide legal, tax, or any other professional guidance. The information is based on research using the best resources available at the time this overview was developed. While we believe the information is accurate, there is no guarantee as to accuracy, timeliness, or relevance of this information. Our goal is, of course, to support Word & Brown brokers and your clients by providing accurate information, although we acknowledge that information is always subject to change.

American Rescue Plan Act (ARP) On Employee Benefits: A Preliminary Overview

American Rescue Plan Act of 2021 | FTA

Source: Word & Brown, by Paul Roberts

On March 11, 2021, President Biden signed the $1.9 trillion American Rescue Plan Act (ARP) into law – a sixth round of long-awaited support and relief from Congress to help Americans deal with the grappling effects of the COVID-19 pandemic. The passage of this law brings significant changes to the health insurance industry, which are arguably some of the biggest we’ve seen since the introduction of the Affordable Care Act (ACA) in 2010.

Because of the buzz created by the law, many are asking about the changes to the employee-benefits and health insurance industries – especially changes to COBRA law.

Laws require regulations, which tell us how the letter (words) of the law will be applied and enforced in real-life situations. Parts of ARPA seem to have some troubling spots, which may conflict with other existing principles and regulations in the industry – particularly in the COBRA space. Regulations and model notices will come from enforcing agencies such as the Internal Revenue Service (IRS) and Department of Labor (DOL) over the next several weeks, which will provide clarity to the law itself – including the troubling areas.

Regulators are working to write the regulations for the new law now, which will provide a deep level of clarity to the many questions about ARPA’s changes. Until then, we can only take a preliminary view of the law based on the letter of the law itself. Stay tuned to the Word & Brown Newsroom for further updates on ARPA and its changes as they become available.

Note that these provisions can, and may, change as regulations follow and further clarity is given. While this article is extensive, it is not intended to be comprehensive of the entire law or other provisions linked closely to it.

ARPA’s significant COBRA change, 4/1/21 – 9/30/21

Arguably ARPA’s biggest change to the employee-benefits industry is in COBRA law, which allows a person who’s lost eligibility for a group health plan the opportunity to continue benefits under that group health plan for a certain duration of time (18-36 months depending on the situation). Federal COBRA law generally applies to employers with 20+ FTEs, based on 50%+ of the typical working days of the preceding calendar year as of 1/1 annually. For more information on this count, refer to Word & Brown’s exclusive Employee Count Reference for California employers and Nevada employers.

While smaller employers of <20 are excepted from federal COBRA, several states (including California, but not Nevada) have “mini COBRA” programs that apply to employers in this smaller segment. California’s mini COBRA law is called Cal-COBRA, which resembles federal COBRA law with several exceptions related to administration, eligibility timeframes, and benefits.

When a person continues a health benefit through COBRA, that person is generally responsible for full payment of the entire gross premium – that is, what the employee contributed and what the former employer contributed for the premium – in addition to a 2-10% admin fee (with exceptions, that can raise the fee as high as 50%). COBRA is often viewed as an impossibly expensive solution to many, because they are surprised to learn the true cost of their premium once the employer’s generous contribution is no longer available. This has been problematic to many during the pandemic, whose bank accounts have been horribly impacted.

The new ARPA law includes 100% federally subsidized federal COBRA premiums for “Assistance Eligible Individuals” (AEIs) for a six month window, from 4/1/2021 – 9/30/2021. AEIs include any person who has lost coverage due to either an involuntary termination of employment or a reduction of hours resulting in the loss of coverage eligibility. A person who voluntarily resigns, or is terminated for gross misconduct, generally does not qualify as an AEI. An AEI otherwise loses eligibility for the subsidy (and thus the AEI status) if offered coverage for another Group Health Plan during the six-month subsidy period, or when becoming eligible for Medicare (generally at age 65).

To subsidize the COBRA premiums, employers with fully insured plans must front payment for COBRA premiums for all AEIs during the 4/1 – 9/30 window, which will be reimbursed later via payroll tax credits by the IRS, applied against employers’ quarterly taxes. If the tax credit payment exceeds the tax amount due, then employers can submit IRS Form 941 for additional funding from the IRS.

As previously mentioned, further regulations will follow on how this will be implemented – as there are many outstanding questions about this from the industry. The IRS will likely develop a form to request advance funds from the IRS to pay for AEIs’ COBRA premiums as needed – though nothing has been announced yet. AEIs are widely expected to take advantage of these subsidized COBRA premiums as they are available, and brokers should prepare employer clients for this as early as possible – keeping in mind that further regulation is required before much further guidance can currently be given other than these preliminary updates.

Under normal circumstances, when a person elects COBRA, there can be no breaks in coverage; continued coverage must begin the day after the coverage was lost. Normally, if COBRA is dropped (including due to non-payment), COBRA is permanently terminated. The COVID-19 pandemic, however, brought many unique challenges to Americans and the economy. Many people who desired to continue their coverage were unable to do so because of the cost. Thus, many people declined COBRA when initially eligible, or dropped it midyear while maneuvering the challenges of the pandemic.

What’s unique (and head scratching to many in the industry) about ARPA’s new COBRA changes is a change to this longstanding “no breaks in coverage” rule within COBRA. Because of the new subsidy, any person who became eligible for COBRA before or during the six-month subsidy period, who is or would be within the typical 18-month COBRA period across the subsidy window, including those who did not initially elect COBRA and those whose COBRA coverage lapsed, is eligible to elect COBRA now to take advantage of the subsidy. A caveat is that those persons must be (or would have been) considered AEIs. And, of course, newly eligible COBRA AEIs can take advantage of the subsidy for any time during the subsidy window, as long as the person is a qualified AEI during the timeframe.

COBRA’s subsidy is not retroactive, can only be used on a go-forward basis, and is only available during the six-month subsidy period. However, any person (qualifying as an AEI) who did not initially elect COBRA or who let COBRA coverage lapse, can elect COBRA now on a prospective basis – meaning COBRA for many will go in effect 4/1/21, even after long breaks in coverage.

Because of the 18-month window provision, this COBRA subsidy could be available to any AEI person with a COBRA qualifying event as far back as November 2019. How carriers will implement this remains to be seen. Like the rest of the country, all of us – including carriers – are looking to regulators to clarify how these changes will work so they can be implemented. It’s important to note that an AEI would also lose eligibly for the subsidy if he or she reaches the end of his or her 18-month COBRA period during the six-month subsidy period.

Employers must notify AEIs in any of these categories about the ability to enroll for coverage, as applicable, during the subsidy window. AEIs will have 60 days to elect COBRA after they receive the required notice from the employer. Because this date goes back to late 2019, employers should begin thinking about tracking down former COBRA-eligible persons to prepare for this notice. As of this article’s publication date, model notices for employers to notify AEIs and to comply with this compliance requirement are not yet written or available. Again, model notices and further guidance will follow from forthcoming highly anticipated regulations.

ARPA also allows employers to implement an optional plan-downgrade option, which would allow AEIs to reduce coverage to less-expensive plans when eligible for COBRA. This is in contrast to COBRA’s other longstanding provision that generally only allows a person to continue the same coverage he or she had the day before experiencing a Qualifying Event (loss of eligibility for the group health plan), except for eligible plan changes at Open Enrollment (and several other exceptions).

Employers have a plethora of new notices to send as a result of these changes, as required by ARPA. The law gives the IRS and DOL a deadline of 4/10/21 to provide all model notices, except the final notice explaining the expiration of the subsidy that is due by 4/25/21. Notices must be sent to inform AEIs of the extended election period, including those who previously experienced a qualifying event but are still in their maximum 18-month coverage period. Per ARPA law, this notice must be distributed by 5/31/2021. Election notices for AEIs eligible for COBRA during the subsidy period must also be revised to reflect these new changes. Lastly, a notice explaining the expiration of the subsidy must be provided to AEIs (unless AEI status is lost due to an offer of alternate group coverage or Medicare coverage) no earlier than 45 days, but no later than 15 days, of the subsidy’s expiration date.

Many California employers are wondering if Cal-COBRA falls under the provisions of federal AEI law. At this point, it is unclear. We will wait for further regulation to clarify in the forthcoming weeks.
Because these COBRA changes are so massive, the ARPA requires Departments of Health and Human Services (HHS), Treasury, and Labor (DOL) to provide public education and enrollment assistance, which will help us learn a lot more about these changes. The departments are targeting education for AEIs, employers, insurers, etc., and will announce plans shortly.

Most employers work with COBRA Third Party Administrators (TPAs) for federal COBRA administration; those TPAs are certainly studying this law to help all employers comply with these items. Like carriers and, frankly, all of us, those TPAs are also awaiting forthcoming regulation so these items can be implemented in their systems and business practices.

Additional ARPA changes in employee benefits

The ARPA contains other significant provisions outlined as follows, with further regulations expected.

Dependent Care FSA election adjustment: Employers sponsoring Dependent Care FSAs (commonly referred to as “DCAPs”) in 2021 will see a raise to the maximum election amount permitted within the plan. DCAPs have had a longstanding maximum election of $5,000 per household. The maximum has been drastically increased to $10,500 per household under ARPA; however, employers must adopt this change at their discretion; it is not mandatory. Employers with 2021 DCAP plans already in existence can retroactively allow employees to increase contributions – though amendments to plan documents most certainly will be required. Currently, this provision lasts for plan years beginning after 12/31/2020 and before 1/1/2022.

Employer tax credits and expanded Paycheck Protection Program (PPP): The Small Business Administration (SBA) added an additional $7.5 billion of funding to its popular PPP program, which provides businesses loans that do not need to be repaid so long as they are used to maintain payroll, which includes employee benefits, and certain other expenses.

Eligibility for PPP has also been expanded into other sectors, non-profits, and labor organizations. Additionally, SBA is extending an additional $15 billion of funds in its Economic Injury Disaster Loan (EIDL) program, also giving priority funding to small employers with fewer than 10 employees. Lastly, IRS’s Employee Retention Tax Credit has been extended through 12/31/2021. This credit originated in 2020’s CARES Act and allows employers to claim a credit for paying qualified wages to employees, against applicable employment taxes.

Paid Leave: 2020’s Families First Coronavirus Response Act (FFCRA), generally applicable to employers with less than 500 employees, provided mandatory paid sick leave and paid emergency family medical leave for persons unable to work or telework for reasons related to COVID-19, also funded by IRS tax credits similar to the new COBRA provisions. While the provisions of this law expired on 12/31/2020, employers were given the option to continue providing FFCRA leave into 2021 at their discretion. ARPA extends the period employers can continue to provide FFCRA-like leave through September 30, 2021. ARPA also added three new qualifications for leave that employers must adopt, if they’ve elected to continue an extension of FFCRA leave in the first place. New covered reasons for leave related to COVID-19 vaccinations are: employee is obtaining a COVID-19 vaccination; employee is recovering from any illness related to receiving the vaccine; or the employee is waiting for a test result/medical diagnosis for COVID-19 either on his own accord or by request of the employer.

Also, as of 4/1/2021, employers may voluntarily offer an additional 10 days (up to 80 hours) of paid sick leave and receive a tax credit for doing so. Lastly, conditions for taking emergency family medical leave under the optional extension of FFCRA-like provisions have changed. Previously, emergency family medical leave only applied to persons who were unable to work or telework because of the need to care for a child whose school of place of care is/was closed due to COVID-19. Under ARPA, emergency family medical leave is now available for all conditions of FFCRA. As such, the maximum tax credit for this type of leave increases from a maximum of $10,000 to $12,000.

Changes to Premium Tax Credits (PTCs)/Subsidies for Individual Plans purchased on a State Exchange (Covered California, Nevada Health Link, etc.): ARPA significantly extends PTCs on the exchange, though only temporarily, through 2022. The new law extends PTCs to higher-income persons who did not previously qualify for coverage in 2021 and 2022. It also increases subsidies to low-income persons during the same timeframe, including providing maximum subsidies for persons receiving unemployment benefits in 2021.

Under normal circumstances, a person is not eligible for a PTC on a state exchange if he or she has a Modified Adjusted Gross Income (MAGI) above 400% of the Federal Poverty Level (FPL). This provision is temporarily eliminated under ARPA in 2021 and 2022; any person who purchases coverage on an exchange can access PTCs regardless of the income they make, as long as their premiums exceed 8.5% of their MAGI. Again, further regulations with additional information will follow – however, the Centers for Medicare and Medicaid Services (CMS) announced these PTCs will be available beginning 4/1/2021, so further regulations/guidance should come soon. As a reminder, a person is generally not eligible for a PTC on a state exchange if an employer of any size makes him an affordable offer of qualified coverage on a group health plan. Kaiser Family Foundation, a highly-regarded bipartisan resource in the health insurance industry, has released a Health Insurance Marketplace Calculator to help consumers understand what types of credits might be available under the new law through 2022.

Extension of Federal Pandemic Unemployment Assistance: The federal government will continue providing $300/week in federal unemployment to eligible persons through September 6, 2021. These funds are generally in addition to funds provided by state unemployment programs. The total number of weeks a person can collect unemployment was increased from 50 weeks to 79 weeks; it is traditionally 26 weeks/year. These unemployment benefits apply to traditionally employed, but not to self-employed – e.g., gig-workers, etc.

As mentioned throughout this column, Word & Brown will keep you up-to-date with breaking changes as they happen – especially as forthcoming regulations are released, providing more context to all items provided by March 2021’s ARPA law.

COVID-19 Infections On The Rise In The Bay Area, Following National Trend

COVID-19 infections on the rise in the Bay Area, following national trend

Source: MSN, by Aidin Vaziri

Coronavirus infections trended up in the Bay Area for the week ending Friday, with the average number of daily new cases at 475, up 8.7% from the prior week ending March 26.

The data could be an indicator that California is beginning to fall in line with the rest of the United States, where coronavirus infections have steadily increased due to more infectious variants.

This is the fourth straight week of rising cases nationwide, according to Dr. Rochelle Walensky, director of the U.S. Centers for Disease Control and Prevention.

“We know that these increases are due, in part, to more highly transmissible variants, which we are very closely monitoring,” Walensky said at a White House press briefing on Monday.

She said young people are driving the latest uptick in infections, as the increasing rate of vaccination in older Americans is preventing the most serious cases among seniors.

Walensky said the agency is watching several outbreaks tied to youth sports and extracurriculars, and urged caution in resuming high-risk activities too soon.

“I understand that people are tired and that they are ready for this pandemic to be over, as am I,” she said. “Please, continue to hang in there, and to continue to do things that we know prevent the spread of the virus.”

In the first week of this year, before a steady downturn began, an average of 4,500 cases was reported in the Bay Area each day. Weekly COVID-19 deaths averaged 78 for the week ending April 4, down from 113 reported the previous week.

But as the region has moved closer to another tragic milestone of 6,000 deaths linked to COVID-19 since the start of the pandemic, some public health experts worry that new cases could pause positive trends in hospitalizations and deaths. Again, the high numbers of older people who now are vaccinated conceivably could keep those numbers from rising as steeply as in pre-vaccine times.

The average number of virus-related deaths reported across California fell from 200 per day on March 28 to 120 on Sunday. And hospitalizations for COVID-19 are at their lowest level in more than a year: about 2,000 COVID-19 patients and 500 in intensive care, a huge drop from early January when those numbers were approaching 22,000 and 4,900, respectively.

As of Monday midday, the death toll in the Bay Area stood at 5,957, data reviewed by The Chronicle showed. Across California, the pandemic has taken 59,279 lives. Nationally the number of lives lost has reached 555,000, according to tracking by Johns Hopkins University.

There is concern that variants could also have an impact on reversing the Bay Area’s progress.

On Sunday, the Stanford Clinical Virology Lab identified and confirmed one case of an emerging variant that originated in India, said Lisa Kim, a spokesperson for Stanford Health Care.

The variant is dubbed the “double mutant” because it carries two mutations in the virus that helps it latch itself onto cells. It could be responsible for the troubling new surge in cases in India, with the nation on Monday reporting its biggest single-day spike, more than 103,000 confirmed cases, since the pandemic began, That topped the previous daily peak of nearly 98,000 cases recorded in late September. India’s death toll is 165,101.

Kim said it is not yet known if the variant is more infectious or resistant to vaccine antibodies than the initial coronavirus. Stanford is screening seven other presumptive cases; the location of the confirmed variant-infected person was not disclosed.

The latest discovery adds to the list of worrisome variants that have made their way to the U.S., including the widely spreading B.1.1.7. variant, which is 50% more infectious. The P.1 strain that originated in Brazil and a variant from South Africa have both been found in the Bay Area, and both are believed to be somewhat resistant to vaccines.

Why Experts Say The Information Blocking Ban Will Be Game Changing For Patients

Interoperability | FierceHealthcare

Source: Fierce Healthcare, by Heather Landi

Starting next week, a new regulation goes into effect that will give patients easier access to their digital health records through their smartphones.

But while health IT experts have been calling for interoperability for years, they say this particular rule could finally be a major step in achieving a meaningful level of data sharing far beyond what’s been seen before in the healthcare sector.

If effectively enforced, the mandate that prohibits information blocking has the potential to revolutionize how patients interact with the healthcare system, said Deven McGraw, a health privacy expert and co-founder and chief regulatory officer at Ciitizen, a consumer health technology company.

“[The information blocking rule] has enormous potential to open up data sources that have previously been closed to patients but hold rich data about patients and that would be potentially game changing for them to tap into and access,” she told Fierce Healthcare.

Micky Tripathi, the new national coordinator for health IT under the Biden administration, recently said the information blocking rules, along with other interoperability rules mandated by the 21st Century Cures Act, represent a “paradigm shift for the industry” by putting patients in control of their health data.

The new information blocking and interoperability regulations will open up an app ecosystem that enables patients to engage with healthcare on their smartphones and through health apps.

“We haven’t broached or embraced that yet,” he said.

“It’s a significant difference from everything we’ve had in the past, in that, it forces a culture change,” Tripathi said.

The rule also enables digital health companies and app developers to access patient data to advance new innovations in healthcare. Over time, the policy could enable patients to integrate all their health data from medical records, fitness trackers, smartwatches and apps to have a more complete picture of their health, industry experts say.

“My teams have heard me say this: COVID changes everything. Information blocking changes everything else,” Dick Flanigan, senior vice president of regulatory affairs at health IT giant Cerner, told Fierce Healthcare. “This gets to what we have all talked about for decades, the digitization of an industry, automation across various players, and the free flow of health information.”

By giving patients access to their health data, there is the opportunity to improve health outcomes, enhance care coordination, increase efficiencies and reduce costs.

“This can have a very large impact as far as patient safety and data accuracy. With data coming from different systems, the right person to mediate that is the patient,” said Jean Tichy, director of clinical solutions at Marshfield Clinic in Wisconsin, during a recent virtual event on the Office of the National Coordinator for Health IT rules.

It could help get rid of fax machines along the way, she said.

But these changes won’t happen overnight, industry stakeholders say.

“When the HIPAA (Health Insurance Portability and Accountability Act) law passed, it took two to four years to get entrenched and to a point where people fully understood it,” McGraw said.

As far as immediate changes, providers shouldn’t expect a tsunami of records requests April 5.

“For the vast majority of patients, it will take a while for it to sink in. I think this will build over time. There will not be thousands of patients banging on their doors to get their data,” she said.

New Double Mutant Coronavirus Variant From India Found In California For First Time

Double Mutant Coronavirus Variant From India Found In California – DeadlineSource: Deadline, by Tom Tapp

Just as California seemed to be on the verge of truly turning the Covid-19 corner, the Stanford Clinical Virology Lab confirmed a case of an emerging variant that originated in India, Deadline has learned.

According to Lisa Kim, Senior Manager of Media Relations for Stanford Health Care, “The Clinical Virology Lab at Stanford Health Care identified and confirmed the newly described ‘India’ variant last week. This variant has the L452R mutation found in the CA variant, as well as another significant spike mutation, E484Q. This same position is mutated to a different amino acid (K) in both the South Africa and Brazil (P.1 and P.2) variants.”

In more conversational terms, that means one of India variant’s mutations is like a key alteration first discovered in the so-called Brazil and South Africa variants. The other mutation is also found in a variant first detected in California, which is by far the state’s most widely-spread new strain.

The news was first reported by the San Francisco Chronicle.

The development is concerning because, for the first time, it combines worrisome mutations from separate, so-called variants of concern.

“This Indian variant contains two mutations in the same virus for the first time, previously seen on separate variants,” Peter Chin-Hong, an infectious disease expert at UCSF, told the Chronicle on Monday. “Since we know that the domain affected is the part that the virus uses to enter the body, and that the California variant is already potentially more resistant to some vaccine antibodies, it seems to reason that there is a chance that the Indian variant may do that too.”

Stanford’s Kim cautions that “it’s not known yet if this variant is more infectious or is resistant to vaccine antibodies.” In fact, despite a surge in cases over recent weeks in India, at the end of March officials there were more concerned about the spread of the U.K. variant than the double mutant, according to AP.

But the news of a new, unusual strain adds an extra dimension to rising concerns about variants in California, especially since one of the mutations is also found on one of the state’s most widespread strains.

As of April 1, California was tracking five variants of concern, including the U.K. (B.1.1.7), Brazil (P.1 and P.2), South Africa (B.1.351) and, of course, its home grown West Coast variants (B.1.427 and B.1.429).

Kim said there had been “one confirmed case” of the double mutant “by [genomic] sequencing at Stanford, 7 presumptive by screening RT-PCR.” Those numbers may not seem like much, but consider this context: In California, only a tiny number of test samples are flagged for genomic analysis.

For example, California has administered over 55 million Covid-19 tests. Of those, less than 50,000 have been flagged by doctors for genomic sequencing. That means that less that .01% of samples have been tested. Granted, those that have been tested were flagged by experts, but in a region of 40 million which is also the most diverse state in the union, such surveillance does not provide dependable insight into how far these variants have spread.

Last Updated 04/14/2021

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