Sequoia Blog
Annual Health and Welfare Non-Discrimination Testing
The Internal Revenue Service (IRS) requires certain health and welfare plans to undergo annual non-discrimination testing to ensure that plans do not discriminate in favor of highly compensated or certain key employees. The non-discrimination test that must be...
Employers Must Distribute Medicare Part D Notices Before October 15th
The Medicare Modernization Act requires all employers to provide written notice to Medicare eligible individuals to notify those individuals on whether their plan provides drug coverage that is “creditable,” or “as good as” Medicare Part D coverage. This allows...
Departments Adopt “Non-Enforcement” Policy on Drug Manufacturer Coupons
On August 26, 2019, guidance was released on the Health and Human Services (HHS) regulation that appears to require group health plans to count the value of drug manufacturers’ coupons towards plan participants’ out-of-pocket limits. The HHS regulation was set to take...
California Passes AB 5, Which May Require Employers to Offer Healthcare to California Workers Previously Classified as Independent Contractors
Updated: On September 18, 2019, California Governor Newsom signed AB 5 into law. Recently, California passed Assembly Bill 5 (“AB 5 or bill”), which lays out a stricter standard for determining whether an individual is legally considered an “independent contractor”...
Certain Employers Must File Health and Welfare Form 5500
Certain employers must submit a Internal Revenue Service (IRS) Health and Welfare Form 5500 ("Form 5500") to annually report certain information on their employee benefit plans to the Department of Labor. Employers with calendar year plans who received a filing...
New York State Announces 2020 Paid Family Leave Rates
New York State Paid Family Leave (NYS PFL) provides employees with job-protected, paid time off to bond with a new child, care for a close relative with a serious health condition, or help relieve pressures when a family member is called to active military service....
Employer Reminder: Plan Administrators Must Furnish Plan Documents Upon Request
Recently, a district court awarded $41,140 to an employee for an employer’s failure to timely furnish health care plan documents upon the employee’s request. This case highlights the legal obligation by plan administrators (who are usually employers) to provide plan...
Updates to Washington D.C. Individual Mandate Reporting Requirements
The Washington D.C. (“D.C.”) Office of Tax and Revenue recently released guidance on the employer reporting requirements under the D.C. Individual Mandate. Employers who provide healthcare to at least 50 full-time employees, including at least one D.C. resident, must...
New York Requires Insurers to Cover Mammograms
On August 2, 2019, New York Governor signed S3852A, known as “Shannon’s Law”, which requires insurers to provide mammograms to certain covered New Yorkers. Shannon’s Law aims to give young women the opportunity to seek early detection of breast cancer by increasing...
IRS Issues Notices to Employers for Late ACA Reporting Submissions
Employers have started receiving Notice 972CG from the Internal Revenue Service (IRS), which proposes penalties on employers for filing their Affordable Care Act (ACA) reporting late or with mistakes. Employers who receive a Notice 972CG should consult with legal...