Sequoia Blog
New Jersey Bans Hairstyle Discrimination
On December 19, 2019, New Jersey Governor Phil Murphy signed the “Create Respectful and Open Workplace for Natural Hair Act” (CROWN Act) to address discrimination based on traits historically associated with race, particularly focused on hair texture and style....
Washington D.C. Paid Family Leave: Official Worksite Poster Released
Background: Enacted in February 2017, the Universal Paid Leave Act of 2016 created the Washington D.C Paid Family Leave program (D.C. PFL or Program). The Program provides up to: 8 weeks to bond with a new child 6 weeks to care for a family member with a serious...
Creditable Status Disclosure Due to CMS within 60 Days of Start of Plan Year
The Medicare Modernization Act requires all employers to complete an Online Disclosure to the Centers of Medicare and Medicaid Services (CMS) to report the creditable coverage status of their prescription drug plan. The Online Disclosure should be completed...
5th Circuit Declines to Decide Whether Entire ACA is Unconstitutional
On December 18, 2019, the 5th Circuit Court of Appeals ruled that the Affordable Care Act (ACA) individual mandate was unconstitutional. However, unlike the lower court, the 5th Circuit declined to decide whether the ACA in its entirety was also unconstitutional. The...
ACA Updates: HIT and Cadillac Tax Repealed, PCORI Fee Extended
On December 19, 2019, Congress passed the 2020 Further Consolidated Appropriations Act (“Act”), which makes the following Affordable Care Act (ACA) changes: The Cadillac Tax was repealed and will never go into effect. The HIT Tax was repealed, effective January 1,...
State-Mandated Short Term Disability Benefits: 2020 Rates
California, Hawaii, New Jersey, Rhode Island, New York and Puerto Rico have mandated short-term disability programs which provide wage replacement to eligible employees. Each state funds their disability program differently, whether it be through employee wage...
Massachusetts Individual Mandate: Employer Reporting and Distribution Due January 31, 2020
The Massachusetts individual mandate requires most residents over the age of 18 to have minimum creditable health care coverage (MCC) or pay a penalty through their state tax returns. Employers who provide MCC to Massachusetts residents are required to distribute...
Massachusetts Paid Family and Medical Leave Private Plan Exemption Update
Background: Beginning January 2021, most workers in Massachusetts will be eligible to receive up to 12 weeks of paid family leave and up to 20 weeks of paid medical leave through Massachusetts Paid Family Medical Leave (“MA PFML” or “the Program”). The Program went...
SF HCSO: Employers with Self-Insured Plans Must Submit any “Top Up” Expenditures by February 29, 2020
San Francisco Health Care Security Ordinance (HCSO) requires Covered Employers to spend a certain amount on Covered Employees’ healthcare. The HCSO has a separate set of rules for self-insured plans that differ from how fully insured plans are treated. For...
Proposed Regulations for the Electronic Disclosure of Retirement Plan Documents
In October, the Department of Labor (DOL) released proposed regulations that would allow plan sponsors (i.e. employers) to furnish retirement plan disclosures to individuals by posting them to a website. The proposed regulations would add a new “safe harbor” to the...