benefits coordination

There is and will be an increased need for employers to understand the various benefits for those who are working and not working and the coordination between them. There are considerations for the following:

If your business is continuing with NORMAL operations

Emergency FMLA Expansion Act (EFMLEA)

The FFCRA applies to private sector employers and public agencies with fewer than 500 employees. It ensures pay for employees unable to work because they are caring for children (under the age of 18) due to school or day care closures due to COVID-19. Please see Emergency FMLA (EFMLEA) and Emergency Paid Sick Leave (EPSLA) Waivers for Employers under 50 Employees and Waivers for Healthcare Providers in the Compliance section of this website.

Emergency Paid Sick Leave Act (EPSLA)

The FFCRA applies to private sector employers and public agencies with fewer than 500 employees. It ensures full and, in some cases, partial pay for employees in a number of situations where they are unable to work due to sickness or caring for children (under the age of 18) due to school or day care closures due to COVID-19. In the case of child care a private sector employer with under 50 employees may be eligible for a waiver. Please see Emergency FMLA (EFMLEA) and Emergency Paid Sick Leave (EPSLA) Waivers for Employers under 50 Employees and Waivers for Healthcare Providers in the Compliance section of this website.

EBSA Disaster Relief Notice

In light of the COVID-19 crisis and its effect on employee benefits, the Department of Labor and IRS have jointly issued a formal rule that extends certain deadlines for group health plans and other welfare benefits.

If your business has REDUCED operations

COBRA Subsidies

Check back here regularly, for updates on the potential of COBRA subsidies being added which is currently under consideration by the administration. This could be similar to the 2008 subsidies that helped people help pay for healthcare.

Post Affordable Care Act (ACA) Health Benefits Access

When required to provide healthcare coverage options to employees losing employer health coverage, due to furlough or layoff, consider promoting government health plans (healthcare.gov) as an alternative to COBRA. The current COVID-19 situation is considered a qualifying event that would allow their enrollment.

Layoff, Furloughs or Reduction in Hours

When employees’ status change, there are important considerations on how to handle benefits – both the offering and how premiums are handled.
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