Student Loan Relief Due to COVID-19

Category: Compliance

Student Loan Relief Due to COVID-19

Posted On: April 2, 2020 | Categorized as: Compliance, Retirement Plans

Overview On March 13, 2020, the U.S. Department of Education announced that it would waive interest charges, allow for suspended payments and provide assistance to borrowers of defaulted loans for a 60-day period. All information can be found at StudentAid.gov. Who Is Affected? All borrowers who have an outstanding federal student loan, including Direct Loans, Federal Perkins Loans and Federal Family Education Loans owned by the U.S. Department of Education can receive relief. What Type of Relief is Available? Interest Waiver • All interest charges on loans are automatically waived starting on March 13, 2020 for a 60-day period. The U.S. Department of Education could extend this period depending on the status of the COVID-19 national emergency. Administrative Forbearance • Borrowers will have the option to go into administrative forbearance. This means borrowers can stop making payments on the loan without risking default for a 60-day period starting on March…


CARES Act Provisions

Posted On: March 27, 2020 | Categorized as: Compliance

On March 27, 2020, Congress passed, and the President signed, an unprecedented 2 trillion dollar stimulus and relief package into law. The law’s nearly 900 pages provide relief for specific industries, including hospitals, airlines, and railroads, as well as cash payments to individuals of up to $1,200 per adult and $500 per child. The bill also contains a number of provisions of direct interest to employers. Small Employers Small businesses (including all businesses under 500 employees and other businesses as defined in section 3 of the Small Business Act and implementing regulations) can qualify for up to $10 million in forgivable loans to be used to cover: Payroll costs (including payments made to independent contractors) during the coronavirus crisis (if employers maintain pre-crisis levels of payroll); Group health benefits, including group health premiums Mortgage interest payments or rent payments Utilities Interest on qualifying debt obligations incurred before the covered period…


DOL Issues Families First Coronavirus Response Act Model Notice

Posted On: March 26, 2020 | Categorized as: Compliance

DOL Issues Families First Coronavirus Response Act Model Notice As required by the Families First Coronavirus Response Act, the Department of Labor has issued a model notice to be posted by employers. The notice is attached here, and should be posted or distributed to employees in its entirety. To assist employers in complying with their posting obligations, the Department of Labor has issued the following FAQs regarding the posting requirement: Where do I post this notice? Since most of my workforce is teleworking, where do I electronically “post” this notice? Each covered employer must post a notice of the Families First Coronavirus Response Act (FFCRA) requirements in a conspicuous place on its premises. An employer may satisfy this requirement by emailing or direct mailing this notice to employees, or posting this notice on an employee information internal or external website. Do I have to post this notice in other languages…


COVID-19: Leave Donation Program

Posted On: March 19, 2020 | Categorized as: Compliance, HR Consulting

Leave donation programs have been considered and implemented by employers for years to allow employees to donate accrued paid time (PTO), vacation or sick leave to a general pool. The time available in this pool serves to be used by fellow employees who have medical emergencies or who are affected by major disasters and have exhausted all paid leave available to them. These programs can provide good-will for employees while serving to fill a need due to unfortunate circumstances. With the advent of the COVID-19 crisis, many employers are considering a Leave Donation Program to lessen the burden of limited Paid Time Off (PTO) available to employees who become ill and to increase camaraderie amongst their employees in the time of a crisis. The rules surrounding a program like this are onerous and can have major tax and compliance implications if not implemented correctly. Here is a summary of rules…


Families First Coronavirus Response Act

Posted On: March 19, 2020 | Categorized as: Compliance

On March 18, 2020, the President signed into law the Families First Coronavirus Response Act. While largely the same as the House bill passed on March 13, the final version of the legislation differs in several material respects from the original legislation, including permitting exemptions for employers with fewer than 50 employees, and providing some limits on the expansion of paid FMLA benefits. In its final form, the act goes into effect starting 4/1/20 and applies to leave taken between 4/1/20 and 12/31/20. See all provisions here. Please contact us with any questions.


ACA Filings for Employers with NJ Resident Employees Due 3/31

Posted On: March 16, 2020 | Categorized as: Compliance

ACA Filings for Employers with NJ Resident Employees Due 3/31 March 16th, 2020 As you may be aware, as of January 1, 2019 the State of New Jersey enacted a mandate requiring New Jersey residents to maintain Minimum Essential Health Coverage, mirroring the requirements of the federal Affordable Care Act. As a result, New Jersey’s Health Insurance Market Preservation Act (HIMPA) has added new cumbersome reporting requirements for employers that have New Jersey residents. These applicable employers are now required to provide the state of New Jersey with the federal 1095 health coverage form for each primary enrollee in 2019, by March 31, 2020. While employers who sponsor a fully-insured health plan are ultimately responsible, we’ve been advised that the medical insurance carriers are fulfilling this requirement on your behalf. For self-insured (which includes level-funded plans), employers should contact their payroll company or ACA reporting vendor to determine if they are providing…


Families First Coronavirus Response Act

Posted On: March 16, 2020 | Categorized as: Compliance

Families First Coronavirus Response Act On March 18, 2020, the President signed into law the Families First Coronavirus Response Act. While largely the same as the House bill passed on March 13, the final version of the legislation differs in several material respects from the original legislation, including permitting exemptions for employers with fewer than 50 employees, and providing some limits on the expansion of paid FMLA benefits. In its final form, the law has several provisions that will take effect in 15 days from signing.  Please see provisions here. The bill provides a series of refundable tax credits for employers who are required to provide the Emergency Paid Sick Leave and the Emergency Paid Family and Medical Leave described above. Subject to certain caps, employers may be able to recover 100 percent of qualified sick leave wages and 100 percent of qualified family leave wages. Innovative is tracking the…


COVID-19 Communicating With Employees

Posted On: March 12, 2020 | Categorized as: Compliance, HR Consulting, Workplace Wellness

COVID-19 Communicating with Employees March 12th, 2020 As part of their efforts to prevent the spread of COVID-19 in the workplace, employers should implement an employee communication plan about the illness to employees. The CDC, WHO and OSHA have all created informational material on the virus and its symptoms, prevention and treatment that can be helpful for employees. Please see table below for key resources.     World Health Organization (WHO) Coronavirus disease (COVID-19) advice for the public   U.S. Centers for Disease Control and Prevention (CDC) Get Your Workplace Ready for a Pandemic (flu-specific but can be adapted to Coronavirus) Pandemic Planning Checklists and Guidance (can be adapted to Coronavirus)   U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) Safety and Health Topics: COVID-19 How to Protect Yourself in the Workplace During a Pandemic   U.S. Department of Labor, Wage and Hour Division (WHD)   Pandemic Flu and the Fair Labor Standards…


Coronavirus And The Workplace

Posted On: March 12, 2020 | Categorized as: Compliance, HR Consulting

Coronavirus And The Workplace  March 12th, 2020 Dealing with Epidemics and Communicable or Infectious Diseases As the number of reported cases of the novel Coronavirus (COVID-19) continues to rise, employers are increasingly confronted with the possibility of an outbreak in the workplace. Employers are obligated to maintain a safe and healthy work environment for their employees, but they are also subject to several legal requirements protecting workers. Compliance issues to consider include: The general duty to provide employees with safe workplace conditions imposed by the federal Occupational Safety and Health Act. Protection against disability discrimination (including disability-related inquiries and medical examinations) under the Americans with Disabilities Act. Requirements set by federal and state employee leave laws; and The compensation of individuals who miss work due to COVID-19. Employers can utilize resources to become educated and to educate employees: What is the Coronavirus? How is the virus spread? Disease Prevention in…


February 2020 Compliance Recap

Posted On: March 6, 2020 | Categorized as: Compliance

February was a busy month in the employee benefits world. The Centers for Medicare and Medicaid Services (CMS) released an updated Premium Assistance Under Medicaid and the Children's Health Insurance Program (CHIP) model notice. CMS also issued frequently asked questions (FAQs) regarding its recently issued summary of benefits and coverage (SBC) template for plan years beginning on or after January 1, 2021. The Department of Health and Human Services (HHS) released a bulletin that allows grandmothered plans to be extended through 2021. The Internal Revenue Service (IRS) released an opinion letter stating that collection of employer shared responsibility penalties under the Patient Protection and Affordable Care Act (ACA) is not subject to a statute of limitations. The IRS also released an information letter confirming that a cafeteria plan is not required to recognize the permitted election change events under the cafeteria plan regulations. The Department of Labor (DOL) issued an…


January 2020 Compliance Recap

Posted On: February 24, 2020 | Categorized as: Compliance

January was a busy month in the employee benefits world. The U.S. Supreme Court (Supreme Court) denied expedited review of a court case challenging the constitutionality of the Patient Protection and Affordable Care Act (ACA). The Supreme Court also granted review of a nationwide preliminary injunction of the November 2018 contraceptive coverage exemptions final rules. The Department of Labor (DOL) issued its annual adjustment of federal civil monetary penalties. The Department of Health and Human Services (HHS) issued its annual adjustment of civil monetary penalties. The Centers for Medicare & Medicaid Services (CMS) released a proposed rule for benefit payment and parameters for 2021. The HHS' Office for Civil Rights released a notice regarding enforcement of individuals' right of access to health records under the Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health Act (HITECH). The Internal Revenue Service (IRS) released Publication…


DOL Increases ERISA Penalties for 2020

Posted On: January 29, 2020 | Categorized as: Compliance

DOL Department Of Labor

January 29th, 2020 On January 15, 2020, consistent with its policy of annual adjustment, the DOL published its final rule adjusting ERISA’s civil monetary penalties for 2020. ERISA protects the interests of employee benefit plan participants and their beneficiaries.  The adjustments are non-discretionary (and therefore not subject to a notice and comment period) and based on the consumer price index from October of 2019. There are five penalty increases of particular importance to employers. Maximum penalty for failure to timely file Form 5500 Maximum penalty for failure to furnish a summary of benefits and coverage (SBC) Failure to comply with the Genetic Information Nondiscrimination Act (GINA) and failure to provide required Children’s Health Insurance Program (CHIP) notices Failure to provide information to the DOL upon request Failure to file form M-1 (for Multiple Employer Welfare Associations or MEWAs) To avoid the imposition of penalties, employers should ensure ERISA compliance for…


December Compliance Recap

Posted On: January 14, 2020 | Categorized as: Compliance

December Compliance Recap

December was a busy month in the employee benefits world. The U.S. Court of Appeals for the Fifth Circuit held that the Patient Protection and Affordable Care Act's (ACA's) individual mandate is unconstitutional. The Internal Revenue Service (IRS) released final instructions and final 1094-B, 1095-B, 1094-C, and 1095-C forms for 2019. The IRS also extended good-faith relief from penalties for employers that report inaccurate or incomplete information on the return or statement for 2019 ACA reporting. President Trump signed the Further Consolidated Appropriations Act, 2020 that significantly affects provisions under the ACA, largely though one fee extension and the repeal of three taxes. The Centers for Medicare and Medicaid Services (CMS) updated its frequently asked questions (FAQs) on Section 111 Medicare Secondary Payer (MSP) prescription drug coverage reporting. The Department of Health and Human Services (HHS) extended the comment period for the coverage transparency proposed rules. The Food and Drug…


The NJ Commuter Benefit Law Coming March 2020

Posted On: January 10, 2020 | Categorized as: Compliance

Public Transit train passing by. NJ Commuter Benefit Law

The NJ Commuter Benefit Law Coming March 2020 January 10th, 2020 The new year comes with many changes for employers, but it doesn't just stop after January.  With the world constantly changing around us, so are the laws that we must follow.  As of March 1st, the New Jersey Commuter Benefit Law will go into affect.  As you may already be aware, employers with more than 20 employees will be required to offer pre-tax commuter benefits to employees.  This new law applies to anyone covered by New Jersey's unemployment insurance law, however employers who hold a collective bargaining agreement are exempt until it expires. What Does This Mean? In short, the new commuter benefits requires employers to offer their employees a choice between taxable compensation or nontaxable qualifies transportation fringe benefits.  Employees must be allowed to choose up to $270 for 2020, which applies to commuter highway vehicles such as…


The 2020 Leap Year Impacting Payroll

Posted On: January 9, 2020 | Categorized as: Compliance

Payroll and salaries for leap year 2020 on desk

The 2020 Leap Year Impacting Payroll January 9th, 2020 As always, the new year comes with a great deal of changes.  With 2020 being a leap year, some of these changes may even be overlooked.  A leap year typically occurs every four years, adding one extra day to the month of February. If you look at your calendar, you'll probably notice that there are twenty-nine days in February, and that is why.  While one day may not seem like a lot, it can effect many aspects of your company, specifically payroll. The Potential Effect On Employers As some of you may be aware, many employers are noticing 27 pay periods instead of 26.  This means that if employers do nothing, they will be providing one additional paycheck, or raise, to employees who are exempt or salaried nonexempt employees.  In short, employers will basically be giving out a raise. Available Options For…


Four Laws That Went into Effect 1/1/2020

Posted On: January 8, 2020 | Categorized as: Compliance

There were several notable laws that effect employers beginning 1/1/2020. It is important for employers to understand how these laws effect your employees and business and any necessary next steps you need to take. As always, your Innovative team will help you understand how these changes will affect your plans and strategy going forward. Please contact us with any questions you may have.        


The ACA’s Cadillac, HIT and Medical Device Taxes Are Repealed; PCORI Fee Extended for 10 More Years

Posted On: December 24, 2019 | Categorized as: Compliance, Employee Benefits

On December 20, 2019, the President signed a $1.4 trillion spending bill that will fund the federal government through September 30, 2020. The bill signed by the President specifically includes the repeal of three major taxes that fund the Affordable Care Act (ACA), including the “Cadillac” tax, the health insurance tax (HIT), and the medical device tax. The excise, or “Cadillac,” tax is a provision of the 2010 ACA law that assesses employer penalties for offering health plans exceeding a certain value, expected to take effect in January 2022. While the Cadillac tax was designed to penalize high-value plans, analyses showed that even moderately priced plans stood to be affected by its implementation. The Cadillac tax has been unpopular with both lawmakers and employers, and its implementation has been repeatedly delayed. With this spending bill, the tax has been fully repealed and will not take effect. Not only does the…


November Compliance Recap

Posted On: December 9, 2019 | Categorized as: Compliance

November was a busy month in the employee benefits world. The Internal Revenue Service (IRS) released draft 2019 instructions for Forms 1094-B, 1095-B, 1094-C, and 1095-C. The IRS also released health plan limits and various compensation, benefit, and contribution levels under qualified retirement plans for 2020. The Department of Health and Human Services (HHS) released inflation-adjusted civil monetary penalty amounts. The Department of Labor (DOL) released advance copies of Form 5500 and related instructions for 2019. The Centers for Medicare and Medicaid Services (CMS) released Summary of Benefits and Coverage (SBC) materials and supporting documents for plan years beginning 2021. A district court vacated the conscience rights protection final rule. The IRS, DOL, and HHS (collectively, Departments) released proposed rules on coverage transparency for health plans and issuers and final rules on price transparency requirements for hospitals. IRS Releases Draft 2019 Instructions for Forms 1094-B, 1095-B, 1094-C, and 1095-C The…


IRS Extends ACA Reporting Deadline for Furnishing Statements for 2019 from January 31 to March 2, 2020

Posted On: December 3, 2019 | Categorized as: Compliance, Employee Benefits

In Notice 2019-63, the IRS extended the 2020 deadline for employers and insurers to furnish individual statements on 2019 health coverage and full-time employee status (Forms 1095-B and 1095-C) from January 31 to March 2. The notice also extends the good-faith penalty relief to 2019 for incorrect or incomplete reports due in 2020. In the Notice, the IRS did not extend the due date for filing the 1094 and 1095 forms with the IRS. If filing by paper, forms are due February 28, 2020, or March 31, 2020, if filing electronically. Please remember that filers can still take advantage of an automatic 30-day extension of the IRS filing deadline by submitting Form 8809 before the relevant due date. IRS indicated that it will continue to require the Filing of Form 1095-B and the completion of Part III of Form 1095-C for 2019. Notice 2019-63 also extends the good-faith relief to 2019. This relief applies to missing and inaccurate taxpayer identification numbers…


Innovative Welcomes Lisa as Director of Compliance

Posted On: November 13, 2019 | Categorized as: Company News, Compliance

We are excited to announce the latest addition to the Innovative Benefit Planning team! Please join us in welcoming Lisa A. Hill as our Director of Compliance.  As Director of Compliance, Lisa will be a valuable resource to Innovative’s leadership team, employees, and clients in ensuring all compliance needs are met. Lisa will be critical in guiding Innovative and our clients through federal, state, and industry regulations and standards. She will be responsible for developing, overseeing, and evaluating control systems to prevent or deal with violations of legal guidelines and internal policies. Moreover, Lisa will be a valuable resource to guide our clients through the proper steps and identify potential liabilities associated with various employee benefits options. Prior to accepting this position, Lisa spent 16 years as an attorney with law firms in California. During that time, she litigated wage and hour class actions and advised clients on such topics…


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