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Compliance Corner

March 2, 2021

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Podcast Episode 99: DOL Deadline Extension Guidance and Potential COBRA Subsidies

In this episode, Chase Cannon and Suzanne Spradley look at recently published DOL guidance establishing new parameters relating to deadline suspensions for COBRA notices, elections and payments, HIPAA special enrollment elections, and appeals/claims filings. Chase outlines the background and examples on the DOL’s new approach to the one-year suspension period, which is now based on the individual’s or plan’s deadline itself (not a hard stop on February 28, 2021, as many had thought). Chase and Suzanne then dig into the newest federal COVID-19 relief bill that is through the House and with the Senate, focusing on potential COBRA subsidies that could create additional employer (and COBRA administrator) compliance obligations.

Every other week, NFP's legal experts make the subject of compliance personal for a wide audience. By breaking down the daunting details of emerging policies and bridging the gap between legislation and what it means for the listener, Chase Cannon and Suzanne Spradley make compliance issues relatable and relevant. Visit our Soundcloud page every two weeks for the most up-to-date episode.

Listen on Google Play Music

March 3 Get Wise Wednesdays Webinar – Register Now

The beginning of 2021 is already getting off to a busy start. With the end of one presidential administration, the beginning of a new one, and an ongoing COVID crisis, there is a lot going on from a benefits compliance standpoint. Join us for a discussion of the most recent government guidance and/or legislation concerning employee benefits.

**This webinar was postponed from February. Thank you foryour patience and understanding.

2021 Benefits Compliance is Like a Box of Chocolates
March 3, 2021
2:00 to 3:00 p.m. CT (3:00 to 4:00 p.m. ET)
Register Now »

A recording will be posted to the NFP Client Learning Portal within 48 hours of the live webinar. Those listening to a recorded webinar aren’t eligible for recertification credit.

All programs are pending approval for 1.0 (general) recertification credit hour toward PHR, SPHR and GPHR recertification through the HR Certification Institute. For more information about certification or recertification, visit the HR Certification Institute website at www.hrci.org.

March 17 Get Wise Wednesdays Webinar – Register Now

Join us as we discuss common HSA compliance matters. Among other HSA topics, we will clarify eligibility rules, discuss the mechanics of HSA contributions, and address how to handle certain mistakes. By the end of the session, participants should better understand HSA eligibility and contribution rules, as well as how to identify and remedy some of the common issues associated with HSAs.

HSAs – How to Maintain Compliance with the Pot of Gold
March 17, 2021
2:00 to 3:00 p.m. CT (3:00 to 4:00 p.m. ET)
Register Now »

A recording will be posted to the NFP Client Learning Portal within 48 hours of the live webinar. Those listening to a recorded webinar aren’t eligible for recertification credit.

All programs are pending approval for 1.0 (general) recertification credit hour toward PHR, SPHR and GPHR recertification through the HR Certification Institute. For more information about certification or recertification, visit the HR Certification Institute website at www.hrci.org.

Reminder: Upcoming IRC 6055 and 6056 Reporting Deadlines

Employers that were ALEs in 2020 must comply with IRC Section 6056 reporting in early 2021. Specifically, ALEs must complete and distribute a Form 1095-C to full-time employees by March 2, 2021 (the IRS changed this from January 31, 2021). The form should detail whether the employee was offered minimum value, affordable coverage during 2020. The forms may be mailed, electronically delivered, or delivered by hand (although proof of delivery in some manner is recommended).

If an employer sponsored a self-insured plan during 2020, it must comply with Section 6055 reporting in 2021. Self-insured employers with 50 or more FTEs must complete Section III of Form 1095-C detailing which months the employee (and any applicable spouse and dependents) had coverage under the employer’s plan. If the self-insured employer has fewer than 50 FTEs, it must complete and distribute a Form 1095-B with such information. Again, the forms must be delivered to employees by March 2, 2021.

Employers must also file the forms with the IRS by March 1, 2021 (as February 28, 2021 falls on a Sunday), if filing by paper, and March 31, 2021, if filing electronically. Those that are filing 250 or more forms are required to file electronically. Lastly, the employer is required to file the transmittal Form 1094-C (if filing Forms 1095-C) or Form 1094-B (if filing Forms 1095-B).

As a reminder, the IRS recently provided penalty relief for employers that will allow them to forego distributing the Form 1095-B to individuals. This comes after the IRS accepted comments on the necessity of the Forms 1095-B now that the individual mandate penalty has been zeroed out. If employers post a notice on their website that the document is available upon request, and fulfil any such request within 30 days, then they will not have to distribute the Forms 1095-B to covered individuals. But keep in mind that there is no such penalty relief for Form 1095-C.

Form 1094-B »
Form 1095-B »
Form 1094-C »
Form 1095-C »
Instructions for Forms 1094-B and 1095-B »
Instructions for Forms 1094-C and 1095-C »

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