January 23, 2019
In this episode, Jill Brooking joins Chase Cannon to discuss the impact the government shutdown may have on employer group health plans, particularly for governmental contractors, whose employees may be out of work due to the shutdown. Jill breaks down the benefits issues employers should look at for employees that are out of work or on furlough as a result of the shutdown, including plan eligibility terms and carrier (or stop-loss) contracts, and the risks in covering employees outside the plan’s eligibility terms. Jill describes how the ACA’s employer mandate may impact an employer’s offer of coverage, depending on whether the employer is using measurement/stability periods for employees. Jill also discusses premium payment options for employers and employees during an unpaid leave of absence, and at what point COBRA comes into play. Lastly, Jill and Chase discuss what should happen when – if ever – the government shutdown ends, including collecting premiums in arrears and the rehire rules under both Section 125 and the ACA’s employer mandate.
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.