Senior Pension Administrator - Combo DB / DC Plans
Primark Benefits
in Burlingame CA / Telecommute

ESOP Administrator
Blue Ridge ESOP Associates
in Charlottesville VA / Telecommute

Client Relationship Manager
Administrative Fiduciary Services, Inc.
in Houston TX / Telecommute

Regional Sales Director
AimPoint Pension
in FL

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COBRA Basics Part 10: COBRA Penalties for Noncompliance
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Text of CMS Guidance: Updated Federal Standard Notices and Enforcement Safe Harbor for Discontinuation Notices (PDF)

43 pages. "[In] connection with the open enrollment period for coverage for the 2020 benefit year, CMS will not take enforcement action against an issuer in the individual market for failing to provide notice of product discontinuation at least 90 calendar days prior to the date of the discontinuation, as long as the issuer provides the notice consistent with this guidance." [Unnumbered document, Jul. 30, 2019] Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]

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HHS Announces New Action Plan to Lay Foundation for Safe Importation of Certain Prescription Drugs

"The Action Plan outlines the government's intention to pursue two pathways to allow safe drug importation from foreign markets: [1] Through a notice of proposed rulemaking (NPRM), HHS and FDA would propose to rely on the authority under current federal law ... that would ... authorize pilot (or demonstration) projects developed by states, wholesalers or pharmacists and submitted for HHS review, outlining how they would import certain drugs from Canada that are versions of FDA-approved drugs that are manufactured consistent with the FDA approval.... [2] FDA would provide recommendations to manufacturers of FDA-approved drugs who seek to import into the U.S. versions of those drugs they sell in foreign countries. Under this pathway, manufacturers would use a new National Drug Code (NDC) for those products, potentially allowing them to offer a lower price than what their current distribution contracts require.... This pathway could be particularly helpful to patients with significantly high cost prescription drugs."
U.S. Department of Health and Human Services [HHS]

A New Day for the HRA

"[DOL, HHS and the Treasury Department] have issued final rules , model notices , model attestations and frequently asked questions that will give employers greater flexibility to offer new types of health reimbursement arrangements (HRAs) for plan years beginning on and after January 1, 2020. The Final Rules provide for two new types of HRAs: the individual coverage HRA and the excepted benefit HRA."
McDermott Will & Emery

Four Essential Elements of a State Approach to Surprise Medical Billing

"Eleven states have already enacted laws giving consumers some protection from surprise medical bills since 2017 ... [S]trategies for states to consider: [1] Work with key stakeholders to understand their unique perspectives.... [2] Prohibit surprise medical billing by out-of-network providers.... [3] Establish limits on reimbursement for surprise medical bills.... [4] Expand application and enforcement of surprise medical billing protections." Arnold Ventures

Policy Options for Addressing High Drug Prices

"[K]ey themes include: ... [1] Making drugs more affordable at the pharmacy, for instance by capping out-of-pocket spending in Medicare Part D.... [2] Shedding light on complex topics like the supply chain, price increases, how prescription benefits managers (PBMs) operate, and potential patent abuses.... [3] Incrementally curbing anticompetitive practices.... [4] Addressing loopholes in previously passed legislation, such as addressing misclassification of drugs by manufacturers to determine the size of the Medicaid rebate." The Commonwealth Fund

Medicare Part D Prescription Drug Plan Costs to Decline Again in 2020

"Over the past three years, average Part D basic premiums have decreased by 13.5 percent, from $34.70 in 2017 to a projected $30 in 2020, saving beneficiaries about $1.9 billion in premium costs over that time. As a result, Part D continues to be an extremely popular program, with enrollment increasing 12.2 percent since 2017." Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]

Senate May Follow House in Voting to Scrap ACA's Cadillac Tax

"Full repeal of the 'Cadillac' tax on 'high-cost' employer-sponsored health coverage is one step closer to reality, after a bill ( HR 748 ) to scrap the [ACA] levy passed the House July 17 in an overwhelmingly bipartisan 419-6 vote.... [Senate] counterpart legislation ( S 684 ) ... now has 50 bipartisan cosponsors: 25 Republicans and 25 Democrats."
Mercer

Dallas Paid Sick Leave Ordinance Faces Legal Challenge

"[T]wo plaintiffs represented by the Texas Public Policy Foundation filed a lawsuit challenging the Dallas paid sick and safe leave ordinance, which is scheduled to go into effect on August [1] It remains to be determined whether the implementation date will be officially delayed -- either through a preliminary injunction or by agreement." Jackson Lewis P.C.

City of Dallas Sued Over Paid Sick Leave Ordinance

"[U]nlike the San Antonio city attorney, the Dallas city attorney was unwilling to enter into an agreement postponing the effective date of the ordinance. But in light of this federal lawsuit and as more Dallas area civic organizations begin putting pressure on the City to delay the ordinance, that position could soften. Right now, it appears that this is headed for a hearing which may, or may not, take place before August 1." FordHarrison

Reviewing Your Independent Auditor's Report: Where to Start

"First, look at the auditor's opinion about the fair presentation of the financial statements.... Next, read the Notes to Financial Statements section.... Third, examine the financial statements themselves for trends in the financial data." International Foundation of Employee Benefit Plans [IFEBP]

Press Releases

Benefitfocus Shortlisted for 2019 SaaS Awards Benefitfocus

Former Pfizer Chief Human Resources Officer Chuck Hill Joins Custodia Financial Strategic Advisory Council Custodia Financial

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Employers Beware: South Carolina Abolishes Common-Law Marriage Jackson Lewis P.C.

Making Sense of the New Auditing Standard for ERISA Plans Ascensus

Text of CMS Proposed Regs: Transparency of Hospital Standard Charges and Other Changes to Medicare Payment Systems Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]