The Vietnam Era Veterans Readjustment Assistance Act (VEVRAA) requires federal contractors and subcontractors to report annually the number of employees who are qualified covered veterans. Information must be provided by job category, hiring location, and new hire status. All nonexempt Federal contractors and subcontractors with a contract in the amount of $150,000 or more with any department of the U.S. government are subject to the reporting requirements.
Q.- We are a start-up company, created in April this year. We just hired our 21st employee. Do we now have to comply with COBRA?
As the end of the summer approaches, Employers should review their seasonal employee hiring. A seasonal employee is an employee who is hired into a position for which the customary annual employment is six months or less. This assumes that by the nature of the position, employment begins and ends approximately the same time each calendar year.
Q.- We have an employee who is continuing coverage under COBRA due to a reduction in hours of employment. The employee has an FSA and an HSA. Can he pay his COBRA premiums through either of these accounts?
Many employers think about privacy and security when they hear HIPAA- the Health Insurance Portability and Accountability Act. HIPAA also gives protections to individuals with respect to their own health information.
The IRS recently released a series of information letters clarifying that the individual and employer mandates under the Affordable Care act remain good law. (IRS Information Letters 2017-10, 2017-11, 2017-13 and 2017-17.)
Q.- We offer medical and dental coverage separately. A former employee continued medical, only. Does he have the ability to add dental coverage under COBRA at our open enrollment?
The U.S. Citizenship and Immigration Services (USCIS) released a new version of Form I-9. All employers use Form I-9 to document and the employment eligibility of newly hired employees.
The Affordable Care Act created a new disclosure requirement for employers- the Summary of Benefits and Coverage (SBC). The SBC is an easy-to-read summary of a health plan, and it must follow a particular format. The SBC is intended to allow individuals to easily compare costs and coverage between health plans. It describes important plan features, such as copayments, deductibles, co-insurance and covered services. The SBC must file a specific format and contain certain examples.
Employers with 50 or more employees must comply with the Family and Medical Leave Act (FMLA). This law provides eligible employees up to 12 weeks of unpaid, job-protected leave for certain family and medical reasons. Group health insurance coverage must continue during the leave.
The IRS has a website dedicated to helping help both individuals and employers with health care reform compliance.
Q.- We offer health coverage to people who work overseas. Do we have to offer them the right to continue their coverage under COBRA?
The IRS released revised versions of Form 1094-B, Form 1094-C, Form 1095-B and Form 1095-C to use for 2017 reporting under the Affordable Care Act. Form 1095-B/C is required to be furnished to individuals by January 31, 2018. Form 1094-B/C is required to be transmitted to the Internal Revenue Service by February 28, 2018 (if furnishing on paper) and by March 31, 2018 if sending electronically. In prior years, the IRS extended these deadlines.
Q.- I am an insurance broker with a company that is completely going out of business. Do they have to offer COBRA to their terminated employees?
As a company grows in size, it is important to keep track of reporting rules that apply with each employee milestone. The larger a company gets, the more reporting typically applies. The list below identifies some requirements that apply based on workforce size. Employers should also remember to consider state reporting requirements.