Summary The almost three-year-old COVID-19 national emergency and public health emergency declarations (Declarations) are slated to expire May 11, 2023. The Upshot The Bottom Line Plan sponsors should use the coming months to work with their advisors and administrators to ensure that their plan design, documents, and communications are appropriately reviewed and, if necessary, revised [&hellip… Continue Reading »
The recently enacted Consolidated Appropriations Act, 2022 (CAA 2022) is best known for preventing a government shutdown and providing aid to Ukraine, but its more than 2,600 pages also contain language that revives a telehealth services provision that many health plan sponsors will welcome. The provision allows participants to receive benefits under a High Deductible Health Plan [&hellip… Continue Reading »
Following up on their earlier guidance the Departments of the Treasury, Labor, and Health and Human Services have issued an additional set of frequently asked questions and answers on the requirement to cover over-the-counter COVID-19 test kits. The new FAQ primarily offers further explanation of a safe harbor approach described in the earlier guidance. This safe harbor generally applies [&hellip… Continue Reading »
The IRS has released Notice 2020-50, which provides guidance to employers that have amended their retirement plans to take advantage of provisions under the CARES Act that provide access to special plan distributions, known as Coronavirus-Related Distributions (CRDs), and expanded plan loans. Coronavirus-Related Distributions The CARES Act permits employers to amend their eligible retirement plans to [&hellip… Continue Reading »
The Internal Revenue Service has issued frequently asked questions (FAQs) clarifying the special distribution options and loan relief provisions applicable to eligible retirement plans and IRAs found in section 2202 of the CARES Act. The following is a high-level overview of the clarifications detailed in the FAQs. A more in-depth analysis of the CARES Act can be [&hellip… Continue Reading »
Allocation of funds under the CARES Act Provider Relief Fund commenced on April 10, 2020, to address the economic impact of the pandemic on the U.S. healthcare system, including the heroic providers battling COVID-19. $26 billion was distributed on April 10 proportionate to providers’ shares of Medicare fee-for-service reimbursements in 2019, and another $4 billion [&hellip… Continue Reading »
Note: This is an update to our April 13 alert here. CARES Act 2.0, signed into law on April 24, 2020, authorized additional funding of certain programs established in the initial CARES Act, including supplemental funding for health care providers. The new law also provides more than $300 billion in additional funding for the Paycheck Protection [&hellip… Continue Reading »
The Centers for Medicare & Medicaid Services (CMS) issued FAQ guidance encouraging health insurers to relax their utilization management and prior authorization requirements in view of the COVID-19 pandemic while at the same time cautioning them to act in accordance with existing guidance. The FFCRA and CARES Act prohibit insurers and group health plans from requiring prior [&hellip… Continue Reading »
The Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (collectively, the “Departments”) have released frequently asked questions (FAQs) for health plans implementing coverage changes under the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The tri-agency FAQs provide helpful and much needed clarifications that [&hellip… Continue Reading »
The CARES Act signed into law by President Trump on March 27, 2020, provides for $100 billion in funding for financial relief to Medicare health care providers impacted by COVID-19. On April 10, 2020, the Administration announced that $30 billion of this funding will be disbursed immediately to providers through direct deposit—these direct deposits will [&hellip… Continue Reading »
On March 27, 2020, Congress passed the CARES Act (the Act), an approximately $2 trillion bill drafted in response to the COVID-19 crisis, with the goal of providing much needed relief for the United States economy. A significant portion of the bill relates to the health care workforce, providing for provisions related to the reauthorization [&hellip… Continue Reading »
The Coronavirus, Aid, Relief, and Economic Security Act, or CARES Act, which passed the Senate last night, is Congress’s third legislative answer to the coronavirus pandemic. The CARES Act represents a heavily negotiated bipartisan effort that now moves to the House, where Speaker Nancy Pelosi has said she will seek swift approval. The CARES Act [&hellip… Continue Reading »
