Forsite Benefits - Blog #COBRA SubsidiesForsite Benefits - Blog #COBRA Subsidieshttps://www.forsitebenefits.com/blogs/tag/cobra-subsidiesFri, 08 May 2026 05:42:51 -0700http://zoho.com/sites/<![CDATA[September 2021: Stay Informed of the Latest HR News]]>https://www.forsitebenefits.com/blogs/post/september-2021-stay-informed-of-the-latest-hr-news
Agencies Plan Changes to Contraceptive Coverage Rules
Additional FAQs & Background on the ARPA COBRA Subsidy
Pfizer-BioNTech Vaccine Fully Approved by FDA​, Monday, August 23, 2021
Filling a Job Vacancy? Five Fast Tips to Make a Job Posting Stand Out

Agencies Plan Changes to Contraceptive Coverage Rules​

On Aug. 16, 2021, the Departments of Health and Human Services (HHS), Labor (DOL) and the Treasury (Departments) issued a frequently asked question (FAQ) regarding enforcement of the contraceptive coverage mandate under the Affordable Care Act (ACA).


This FAQ indicates that the Departments intend to amend existing religious and moral exemptions to the contraceptive coverage mandate in light of recent litigation.


Contraceptive Mandate

The ACA requires non-grandfathered health plans to cover certain women’s preventive health services without cost sharing, including all FDA-approved contraceptives.


Religious exemptions apply to certain churches, houses of worship, and other church-affiliated institutions, allowing them to choose not to contract, arrange, pay or refer for any contraceptive coverage.


On Nov. 15, 2018, the Departments published final regulations that expanded the exemptions and accommodations to the contraceptive mandate to apply to any entities with religious or moral objections to the contraceptive coverage requirement.

On July 8, 2020, the U.S. Supreme Court upheld these regulations as a valid exercise of power under the Trump administration.


FAQ Guidance

The FAQ indicates that the Departments intend to issue regulations within six months to amend the 2018 final regulations. The FAQ does not provide any additional detail or specify the types of changes that may be made.

Additional FAQs on the ARPA COBRA Subsidy​

On July 26, 2021, the IRS issued Notice 2021-46, providing additional guidance on the application of the American Rescue Plan Act (ARPA) subsidy for continuation health coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA) in the form of 11 questions and answers.


The Notice expands on prior guidance issued on May 18, 2021.


Background

The ARPA subsidy covers 100% of COBRA and state mini-COBRA premiums from April 1–Sept. 30, 2021, for certain assistance-eligible individuals whose work hours were reduced or whose employment was involuntarily terminated. The subsidy is funded via a tax credit provided to employers, insurers or group health plans, according to the terms of the statute.

  

Q&A Topics

The questions addressed include:

  • Subsidy availability to individuals eligible for an extension who had not elected it;
  • Whether subsidies for vision or dental-only coverage ends due to eligibility for other coverage that does not include vision or dental benefits;
  • Subsidy availability under a state statute that limits continuation coverage to government employees;
  • Whether employers may claim the tax credit if the Small Business Health Options Program (SHOP) Exchange requires employers to pay COBRA premiums; and
  • Which party may claim the tax credit in situations involving parties other than an insurer or former common law employer providing the COBRA coverage.

COBRA Subsidy Expiration Notice Due by Sept. 15 (Sooner for Some)

The American Rescue Plan Act (ARPA) provides COBRA premium assistance to eligible individuals and imposes notice requirements on health plans, including a requirement to notify eligible individuals about when their premium assistance ends.

The notice of premium subsidy expiration must be provided during the 45 - 15-day period before an individual’s subsidy expires. This means that, for individuals whose subsidy is expiring due to the end of the subsidy period, the notice must generally be provided from Aug. 16, 2021, to Sept. 15, 2021. Otherwise, the due date will depend on when an individual’s maximum COBRA coverage period ends.

Plans are not required to issue an expiration notice to individuals whose subsidy is expiring because they became eligible for other group health plan coverage or Medicare.

Pfizer-BioNTech Vaccine Fully Approved by FDA​

On Monday, Aug. 23, 2021, the Food and Drug Administration (FDA) gave full approval to the Pfizer-BioNTech coronavirus vaccine.


It is the first full approval of any coronavirus vaccine in the United States. The other vaccines, Moderna and Johnson & Johnson, are still available under emergency use authorization (EUA) granted by the FDA. The Moderna vaccine is currently under review for full approval, and the Johnson & Johnson vaccine is expected to begin the process soon.


"The Pfizer-BioNTech vaccine is fully approved for individuals aged 16 and older. The vaccine also continues to be available under the EUA for children ages 12 to 15 and for the administration of a third dose in certain immunocompromised individuals.

“While millions of people have already safely received COVID-19 vaccines, we recognize that for some, the FDA approval of a vaccine may now instill additional confidence to get vaccinated.”

- Dr. Janet Woodcock, the acting FDA commissioner


The approval comes as the coronavirus Delta variant continues to spread across the United States. Federal and state governments have been issuing renewed guidance as a way to rein in the infections, including implementing stringent mask-wearing requirements.


What’s Next?

Authorizing the Pfizer-BioNTech vaccine is expected to open the floodgates for employers considering their own vaccine requirements. Many colleges, hospitals, corporations and even the federal government have announced tentative plans to require proof of vaccination as a condition of employment. United Airlines, for example, recently announced they will require vaccine proof among their employees. Other businesses are using vaccine cards to verify whether patrons need to wear face masks.


It is unclear how many organizations will require vaccination among employees in the near future, but employers should continue to monitor the situation as it evolves. We will be sure to keep you up to date on any new developments.

How to Make Your Job Posting Stand Out​

Filling a job vacancy is a big task. Unfortunately, you get only one chance to make a first impression, and the job posting is often your very first contact with a potential employee. But how do you make your job posting stand out above the rest? 


Here are five fast tips >> to make your job posting stand out.

Keep Employees Connected, Engaged, & Healthy with Forsite EXP >>

Forsite EXP is the ultimate employee experience platform. This customizable app helps employers reach employees on their smartphone with important company updates and healthcare education, and provides benefits support as they navigate unique healthcare needs.


   LEARN MORE ABOUT FORSITE EXP >>                             

The content herein is provided for general information purposes only, and does not constitute legal, tax, or other advice or opinions on any matters. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy.

Copyright © 2020 HR 360, Inc. All rights reserved.

]]>Fri, 27 Aug 2021 12:07:49 -0500<![CDATA[June 2021: Stay Informed of the Latest HR News]]>https://www.forsitebenefits.com/blogs/post/june-2021-stay-informed-of-the-latest-hr-news
IRS FAQs and COBRA Subsidies
IRS Releases Updated 720 Form For PCOR Fees
Protecting Employees From Burnout
Hiring and Managing Seasonal Employees

IRS Issues Guidance on Taxability of DCAP Benefits for 2021 and 2022

On May 10, 2021, the Internal Revenue Service (IRS) released guidance >> on the taxability of dependent care assistance programs (DCAPs) for 2021 and 2022, clarifying that amounts attributable to previously issued carryover and extended grace period relief >> generally are not taxable.


Specifically, if these dependent care benefits would have been excluded from income if used during taxable year 2020 (or 2021, if applicable), these benefits will remain excludible from gross income and are not considered wages of the employee for 2021 and 2022. They will also generally not be taken into account for purposes of applying the exclusion limits of Internal Revenue Code Section 129.

Here is an Example

IRS Notice 2021-26 clarifies the interaction of this standard with the one-year increase in the exclusion for employer-provided dependent care benefits from $5,000 to $10,500 for the 2021 taxable year under the American Rescue Plan Act.


Here are the Facts

Employee elects to contribute $5,000 for DCAP benefits for the 2020 plan year but incurs no dependent care expenses during that plan year. The employer amends its plan to allow the employee to carry over the unused $5,000 of DCAP benefits to the 2021 plan year. The employee elects to contribute $10,500 for DCAP benefits for the 2021 plan year, incurs $15,500 in dependent care expenses for that plan year, and is reimbursed $15,500 by the DCAP.


In Conclusion

The $15,500 is excluded from the employee’s gross income and wages because $10,500 is excluded as 2021 benefits and the remaining $5,000 is attributable to a carryover permitted by the previously issued coronavirus-related relief.

​​IRS FAQs on COBRA Subsidies

The Internal Revenue Service (IRS) has published frequently asked questions (FAQs) on the application of the American Rescue Plan Act (ARP) subsidies for continuation health coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). The FAQs cover a wide range of topics.


Background

The ARP subsidy covers 100% of COBRA and State mini-COBRA premiums from April 1–Sept. 30, 2021, for certain Assistance Eligible Individuals whose work hours were reduced or whose employment was involuntarily terminated. The subsidy is funded via a tax credit provided to employers, insurers or group health plans, according to the terms of the statute.


Frequently Asked Questions

Among the topics covered are how to calculate and claim the tax credit, including when a third-party payer is involved. According to the guidance, employers must document individuals’ eligibility for COBRA premium assistance to claim the credit. The FAQs further clarify that:

  • The subsidy is available for extended periods of COBRA coverage between April 1 and Sept. 30, 2021, due to a disability, second qualifying event or extension under State mini-COBRA.
  • Involuntary termination includes constructive discharge and termination for cause, but not gross misconduct.
  • Health reimbursement arrangements, dental-only plans and vision-only plans are covered by the subsidy.


Action Steps

Employers should review the IRS FAQs in their entirety to ensure compliance with the ARP, especially with respect to notice and documentation obligations.

Did you know the average Human Resources professional spends 25 hours a month simply doing research? There's a resource for that! 

Visit the Forsite Resource Lounge >>

​IRS Releases Updated Form 720 for PCOR Fees​

The IRS has released a revision to IRS Form 720, which is used to pay the Patient-Centered Outcomes Research (PCOR) fees due July 31, 2021.


Each year, employers must wait for the IRS to update Form 720 to pay their PCOR fees using the correct form. The PCOR fee is used to fund research on patient outcomes. As part of the Affordable Care Act, employer-sponsored health plan(s) are subject to PCOR fees. 


The PCOR Fees due by July 31, 2021 include plan years ending in 2020.

  • For plan years ending on or after January 1, 2020 through September 30, 2020 the fee is $2.54 per covered life.
  • For plan years ending on or after October 1, 2020 through December 31, 2020 (including calendar year plans) the fee is $2.66 per covered life.

PCOR Fees for self-funded major medical plans, HRAs, and non-excepted Health Care FSAs are payable by the employer using IRS Form 720 and are due July 31.

[this information has been provided by Employee Benefits Corporation's Compliance Buzz]

The IRS provided transition relief related to the 2020 PCOR fee calculation, due to the anticipated termination of the PCOR fee prior to its extension. This transition relief allowed issuers and plan sponsors to use any reasonable method for calculating the average number of covered lives for this period, in addition to existing methods, so long as it was applied consistently for the duration of the plan year. However, this transition relief was not extended for the 2021 plan year. As a result, plans and issuers must use one of the existing methods for calculating the PCOR fee for 2021. 

Protecting Employees From Burnout​

Burnout has been a commonly discussed issue amid the COVID-19 pandemic. Oftentimes, it is the Human Resources department's responsibility to help employees cope with burnout and its contributing factors. 


Burnout, in simple terms, is the feeling of mental exhaustion stemming from workplace duties. According to the World Health Organization, burnout may be shown through the following symptoms:


  • Fatigue or energy depletion
  • Decreased engagement at work, or feelings of negativism or cynicism related to one's job
  • Reduced productivity or efficacy
  • As these examples show, burnout doesn’t always look the same for everyone. Yet, the impacts of burnout are typically uniform—lower-quality work and detrimental health effects.


4 Steps You Can Take to Help Your Team Recover From or Avoid Burnout Altogether

  • Meet regularly with team members and peers to gauge their emotional states and discuss individual work duties as needed.
  • Recognize and celebrate individual and team achievements.
  • Train other managers on how to keep employees engaged and motivated at work, and how to spot signs of burnout.
  • Clearly communicate that employees should reach out if they are experiencing burnout, and that there will be no punishment for seeking help.


Your team is made up of many unique individuals, each with different needs that should be met in order to recover from or avoid burnout. Consider what actions you can take as a team leader and mentor to meet their diverse needs and build up a supportive and productive workplace culture.

Keep Employees Connected & Encourage Healthy Habits with Forsite EXP >>

Forsite EXP is the ultimate employee experience platform. This customizable app helps employers reach employees on their smartphone with important company updates and healthcare education, and provides benefits support as they navigate unique healthcare needs.


   LEARN MORE ABOUT FORSITE EXP >>   

Hiring and Managing Seasonal Employees​

With the summer hiring season underway, employers should begin thinking about how best to hire and manage seasonal employees. Employers who do not dedicate time to these critical steps risk having to face disgruntled employees, unhappy customers, and even legal violations. 


To learn some best practices for hiring and managing seasonal employees, please watch this video >>>.


Read May's HR newsletter >> for 4 virtual recruitment strategies.


The content herein is provided for general information purposes only, and does not constitute legal, tax, or other advice or opinions on any matters. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy.

Copyright © 2020 HR 360, Inc. All rights reserved.

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