2026 Benefits Compliance Midyear Check-In

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Amber Posthauer: Hello, everyone! Thank you for joining us today. We're going to get started here in 60 seconds to allow for everyone to get connected. We'll get started shortly.

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Amber Posthauer: Welcome, everyone, to the 2026 Benefits Compliance Midyear Check-In. Thank you all so much for joining us.

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Amber Posthauer: The Benefits Compliance Team will be answering the questions you send through the Q&A today. We'll try our best to answer all of your questions, but if for whatever reason we're unable to get to your question today, please follow up with your advisor for further assistance.

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Amber Posthauer: Today's presentation is being recorded. We'll be sharing the recording in the follow-up email and on the NFP website. If there are any portions of this call that you missed by Monday, you'll receive an email with a link to the full recording. The PowerPoint slides used during this presentation will be shared in the same email.

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Amber Posthauer: At this time, I'll hand it over to David Rotman, Vice President and Council of NFP Benefits Compliance, and Jessica Waltman, Regional Vice President of the Northeast Region of NFP Benefits Compliance. Jessica, the floor is yours.

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Jessica Waltman: Thank you, Amber. Before we get started, I just want to give You all, a reminder… That… the…

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Jessica Waltman: We are not your attorneys here at NFP, so neither David nor I are providing you with legal advice, and we are also not your, tax advisors, so we cannot give you tax advice either.

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Jessica Waltman: And we also… I know that, we're going to be talking about some moving targets today, but, we have tried very hard to keep this information current as of August 19th today, but…

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Jessica Waltman: Please know that any of the topics we talk about today are possible to change. Again, as Amber said, if you have any questions, please put them in the Q&A, and members of our compliance team will be on hand to answer them. And then we're also going to put a PDF version of the slides.

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Jessica Waltman: in that Q&A for you as well, so you can access them, plus you'll be able to get them next week with the recording.

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Jessica Waltman: So…

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Jessica Waltman: Oops, sorry. For some reason, these slides were not advancing the way that I would like.

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Jessica Waltman: But moving on to our agenda for today, we have a lot of great topics for you, kind of 4 segments.

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Jessica Waltman: First, David's going to talk about the elections that are coming up on the federal level this November, and how those midterm elections may impact the health policy agenda and group health plans moving forward.

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Jessica Waltman: Then, I'm going to chat with you about pending federal legislative and regulatory activity.

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Jessica Waltman: And then David is going to talk to you about recent developments in state-level paid leave.

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Jessica Waltman: And then I'm gonna wrap it up with talking about health plan eligibility, and how keeping that tight can really make a big difference in your plan administration, your compliance, and also your plan costs. So, and then David will wrap things up.

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Jessica Waltman: So as Amber mentioned, I'm Jessica Waltman. I am one of our Vice Presidents of Benefits Compliance here at NFP,

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Jessica Waltman: And I specifically work with clients and account teams in our Northeast region, so if we have any Northeast folks on today, thank you so much for joining. You may have worked with me in the past.

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Jessica Waltman: And with me, I am thrilled to be with my friend and colleague, David Rotman, who is also on our compliance team as the Vice President, and David works on many of our compliance publications that you get to utilize, and he's also our team subject matter expert.

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Jessica Waltman: On leave matters, so that's why he'll be talking to you about paid leave.

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Jessica Waltman: So with that, I'm going to kick it over to David so he can start talking to you about our upcoming federal elections.

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David Rotman: Thank you, and good afternoon, everyone.

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David Rotman: So, as we approach the 2026 congressional midterm elections in November, there has been a growing focus on healthcare, tax policy, and workforce issues.

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David Rotman: All seats in the U.S. House of Representatives and 35 seats in the U.S. Senate will be on the ballot in November, and the outcome of the election will likely be a key determinant of the federal health and Benefits Policy Agenda for the remainder of this administration.

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David Rotman: And as we saw last year, the legislative deadlocks surrounding the future of AC premium tax credits and Medicaid ultimately resulted in American history. And earlier this year, the administration announced its proposed healthcare agenda.

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David Rotman: But much of the plan is contingent on congressional action.

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David Rotman: So the outcome of this November's midterms will remain vital for any real progress on healthcare moving into 2027.

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David Rotman: Slide.

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David Rotman: So, looking more closely at the current political breakdown, Republicans currently hold narrow majorities in both chambers, and even modest seat shifts

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David Rotman: this fall could change congressional control. Historically, the administration's party has tended to lose House seats in midterm elections, so it's possible that control of the House could change with only a small net shift because of the current narrow Republican majority.

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David Rotman: The most competitive races in the House are expected to be in suburban swing districts, and in districts that were won narrowly in the 2024 election.

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David Rotman: But looking more specifically at policy objectives, Republican candidates have been advocating for greater emphasis on market-based health reforms, as well as expansion of health savings account initiatives. They have also supported the increased scrutiny of federal benefit mandates.

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David Rotman: On the Democratic side, candidates have been supporting an increased focus on ACE-related affordability and coverage issues, and greater oversight of employer health plans and pharmacy benefit managers.

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David Rotman: Slide.

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David Rotman: So, looking specifically at the Senate, there are 35 seats that are up for election in November, including special elections in Florida and Ohio. These include 22 seats currently held by Republicans and 13 held by Democrats.

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David Rotman: Democrats are facing a challenging map in several competitive states, and Republicans are defending more total seats, but will begin with a majority advantage. Some of the biggest Senate battleground states are expected to be in Georgia, Michigan, Arizona, and Nevada, among others.

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David Rotman: However, as with the House, modest seat shifts could change… could change Senate leadership heading into 2027.

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David Rotman: So, what would be the outcome if there is a party change in the leadership in the House, the Senate?

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David Rotman: If the election does result in a change in leadership, legislative changes may ultimately become more difficult due to the political division there might be. The effect of this is that employee benefit reforms and compliance activity

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David Rotman: will be more likely to come through federal agencies and regulatory guidance than through major legislation. Nonetheless, the election outcome could influence things like HSA expansion efforts, ACA-related requirements, federal paid leave initiatives, as well as retirement and tax legislation.

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David Rotman: And with that, I'll turn it back over to you, Jessica.

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Jessica Waltman: Okay, well, thank you, David. So, I think what I heard you say was that Congress is very divided right now, right?

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Jessica Waltman: And, I know that you mentioned that if we have a change in leadership, it could get even tougher, and that what we will be focusing on more is regulatory activity, but the Congress is already divided.

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Jessica Waltman: And so, we've seen, very few, or really no, laws recently passed that truly impact group health plans, but what we have seen is a lot of regulatory activity.

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Jessica Waltman: So I'm gonna go through some of the most recent regulatory activity, and then also talk about some of the pending federal legislation that could move forward.

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Jessica Waltman: And I'm going to start with the matters that actually have been finalized, and then I'm going to go through this… the, actions that are in various stages of being proposed, and could come into play, later this year or next year.

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Jessica Waltman: So, the first thing that I'm gonna start with is our benefit plan limits for 2027. And many of those are final, and we know what they will be, so how they will impact your group health plan next year.

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Jessica Waltman: So we already have all of the limits related to health savings accounts and their related qualified high-deductible health plans. We've got the maximum out-of-pocket limits for next year, so what

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Jessica Waltman: And a plan participant can expect to spend no more than this in out-of-pocket costs, cost sharing, deductibles, and what have you.

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Jessica Waltman: For both high-deductible health plans and other types of coverage. And then, most recently, we got the ACA affordability percentage that came out, earlier this summer.

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Jessica Waltman: So, that is really, relevant to any employer who is considered an applicable large employer and subject to the ACA's affordable, employer mandate.

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Jessica Waltman: And, as you can see, for 2027, that amount went up to 10.22%, so that's the first time since the employer mandate went into effect in 2015 that that number went above 10%. And why is that relevant? What does it mean to you?

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Jessica Waltman: Well, when you are setting up your premium contribution rates and deciding what the employer pays and what the employees pay, if you're subject to the employer mandate, you're going to pay very close attention to what the maximum amount you can charge employees.

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Jessica Waltman: and still maintain, you know, mitigate your employer mandate liability, or potential for a penalty. So this year, it's 10.22%. So that means that an employer can look at an employee's,

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Jessica Waltman: Household income, and monthly they can charge them no more than 10.2% of that for their premium share, and if they go over that, then they have mandate liability.

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Jessica Waltman: Now, of course, employers don't usually know what their employee's full household income is, so typically, employers rely on one of three safe harbors.

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Jessica Waltman: So with that amount going up a little bit, it actually gives a greater amount that employers can cost shift onto the employee in terms of the monthly premium.

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Jessica Waltman: And that cost shifting is really only relevant to the lowest cost minimum value plan that the employer offers, and we're looking at the employee-only rate, regardless of what type of plan option the employee actually picks. That's the one that needs to meet that affordability criteria.

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Jessica Waltman: So just to give you, an idea of what that would be monthly, if you use the federal poverty level safe harbor, that amount would be $135.92 per month. That would be the maximum employee contribution

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Jessica Waltman: Under that safe harbor. There are two other safe harbors that many employers use, rate of pay and W-2 wages. Those are… you can't calculate them, for all employees ballpark. You need to use their actual income amounts, but, they usually give you a little bit more room, so the employee.

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Jessica Waltman: federal poverty level Safe Harbor is usually the lowest one. So you're gonna know you can use that as kind of a benchmark when you're thinking about where to send your premium contributions for next year.

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Jessica Waltman: If you are a calendar year plan and an applicable large employer, that's the percentage you'll use for all of next year. If you,

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Jessica Waltman: reset your plan and renew sometime during the middle of 2027. You use that existing 9.96% for now, and then you change it when you renew your plan year.

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Jessica Waltman: So this is many of the limits that we are looking for. There are a few more that we are waiting for the federal government to finalize, notably the FSA limits, and then also commuter benefit limits, and they typically come out later in the fall. So as soon as we have those, we'll let you know what they are.

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Jessica Waltman: Another new thing that is really breaking news, that is final, that will affect your group plans right now, is a new rule that the Trump administration put out

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Jessica Waltman: last week, on August 11th. Now, typically, when an administration issues a proposed rule, it is really just released as a rough draft, and they say, we're taking comments on it, and we will get to finalizing it later after we assess all of your comments, and it's just a rough draft, you do not rely on it.

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Jessica Waltman: This rule that just came out is fairly unique, because the administration told us when they released it that employers can use it right now.

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Jessica Waltman: So, they are still taking comments. It might change a bit as they work to finalize it, but we can use these standards that they just issued today.

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Jessica Waltman: So there was two parts to it.

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Jessica Waltman: The first, addresses the Trump accounts, which are a new type of, sort of like an IRA vehicle that the Trump administration created, just in the second, iteration of the Trump administration, and…

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Jessica Waltman: Right, available for newborns. For the next few years, the administration is providing funding for them. However, they had announced earlier that their intent was to expand those accounts and allow employers to contribute to them.

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Jessica Waltman: So this proposed rule does allow that, and so it sets out the criteria that employers need to follow to contribute to an employee or an employee's dependent's Trump account.

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Jessica Waltman: So it allows an employer to give up to tax-free up to $2,500 per year, and that will be annually adjusted. The rule also sets out a lot of requirements that employers would need to do to

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Jessica Waltman: put in this type of program. I'm not going to go into a ton of detail about them now. You can get more information available about them at the Trump account website, which is linked in the slides.

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Jessica Waltman: The reason why I'm not going to go into a lot of detail is it's our understanding that while the rules themselves are final, the infrastructure for employers to actually be able to give those contributions starting

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Jessica Waltman: in January of 2027 is still being built, so it's not… even though you can rely on the information in the rules today, it's not something that employers could start doing as of today. So that's… we're going to work on… I believe they're going to work on that over the next coming months.

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Jessica Waltman: What CAN affect your plan today is the new rules on non-discrimination testing for dependent care assistant programs, or DCAPs.

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Jessica Waltman: These are the benefit plan option that employers can put into effect to allow employees to put money aside pre-tax.

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Jessica Waltman: for, applicable child care expenses. And those, account-based plans need to be tested so, they don't favor, you know, inadvertently or, or.

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Jessica Waltman: You know, intentionally highly compensated employees. So we can't discriminate in favor of those highly comped individuals.

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Jessica Waltman: And there's actually never rules on DCAP non-discrimination testing before, so they're new. Previously, we relied on the statute and some of the other related account-based plan rules to tell us how to do that testing. And there were some wrinkles in that testing.

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Jessica Waltman: And employees were fairly likely to fail it. A lot of times, employers have stopped offering DCAP,

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Jessica Waltman: Plans because they've had high failure rates.

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Jessica Waltman: Now.

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Jessica Waltman: There's a couple reasons why there are high failure rates with the decaps, and one of them is just the way that the program is structured through the statute. You have to put the money aside first, and it's only after you've put the money aside that you can get reimbursed for your expenses.

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Jessica Waltman: So, just that structure makes it more likely that someone who makes more money is, you know, seeing the advantages to that type of an account.

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Jessica Waltman: However, there was another wrinkle to it that made the failure rate probably a little bit higher than some of the other plan options that you might offer. And specifically, there was a 55% average benefit test, which still exists.

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Jessica Waltman: But we used to, in testing, look at anybody that could be eligible for a DCAP plan, even if they didn't elect to use the benefit.

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Jessica Waltman: This new rule says, no, when you're doing the non-discrimination testing, you look at, the participation of actually the people who are actually putting the money aside.

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Jessica Waltman: not just anybody who might be eligible. So it really narrows down the amount of people that are subject to the test, potentially making it easier for a, employer plan to pass.

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Jessica Waltman: And not have to cap benefits or tax benefits for highly compensated employees.

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Jessica Waltman: We also get an exclusion out of this for any employees that earn less than $25,000 a year. They will not be subject, you know, they can exclude them from the testing population. And then the final change, that was

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Jessica Waltman: noted in this rule was how, if a group does fail the, benefits test or the owner concentration test, that rather than taxing the entire amount, that the highly compensated individual put aside.

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Jessica Waltman: we would just tax the excess amount, so what caused the failure. So that would reduce the tax burden on those highly compensated employees, should there be a failure.

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Jessica Waltman: So that is something, again, that is in effect as of last week. So you may be hearing about this from your account-based plan vendors. It may be something to take into consideration if you had an offer to DCAP previously, or you had eliminated it due to testing failures.

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Jessica Waltman: And it's something that you're going to want to talk to your NFP consultants about.

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Jessica Waltman: Okay.

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Jessica Waltman: So the next one is really, very exciting for benefit plan nerds, for people like me.

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Jessica Waltman: So, as you all might know, the foundational law that, establishes and all the rules that we follow for health and welfare plans stems back to a pretty old law.

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Jessica Waltman: 52 years old, I can say this because we're both the same age. ERISA goes back to 1974, but it's called ERISA.

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Jessica Waltman: And when ERISA was passed, it was a little beyond Pony Express days, but we were still handing out documents, either in person or sending them through regular U.S. mail.

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Jessica Waltman: So that was the way that ERISA wants you to deliver all of its required documents that need to go to plan participants and plan notices.

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Jessica Waltman: 2002, which to me feels like just only a few years ago, but it was really 24 years ago, ERISA allowed a,

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Jessica Waltman: Safe harbor for disclosing documents to plan participants electronically.

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Jessica Waltman: So, even though it seems not that far away, that was actually back in the days of dial-up internet stall, and no smartphones, email was just a baby, so the rules related to electronics disclosure are definitely now very out of date.

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Jessica Waltman: The good news is that this past July, just a few weeks ago, the Department of Labor issued new rules proposing a new kind of electronic disclosure safe harbor.

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Jessica Waltman: And those rules would really make it much easier for plan sponsors like you to send out documents, post documents, and provide them to your plan participants.

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Jessica Waltman: That's the good news.

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Jessica Waltman: The bad news is that when they made this proposal, they only focused on the group health plan.

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Jessica Waltman: So they left out life plans, short-term disability, long-term disability, other benefit options that don't fall into that definition of a group health plan.

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Jessica Waltman: What they forgot was that most employers

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Jessica Waltman: When they're doing their plan documents, wrap together

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Jessica Waltman: many kinds of benefits. So they often wrap together the health plan.

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Jessica Waltman: With the life plan, the, you know, the group life plan, the short-term disability, and what have you.

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Jessica Waltman: So, if you had a wrap document under the current rules.

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Jessica Waltman: the current proposed rules, they're not in effect yet. You wouldn't be able to use it very effectively, because anything that

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Jessica Waltman: had a notice, like a summary annual report for your 5500, or your summary plan description, if you had a rep benefit plan, they wouldn't be able to use that new safe harbor to be delivered, because they had those other pieces attached.

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Jessica Waltman: So, what's happening? First of all, the Department of Labor recognizes this as a rough draft, and they are asking for comments on it through September 21st.

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Jessica Waltman: So NFP and our trade association partners in Washington, D.C, are working with the Department of Labor about this, kind of explaining the little shortfall here, how it could very easily

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Jessica Waltman: be corrected and expanded. We're working on those comments, and we're trying to get them to come around to expand out that role.

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Jessica Waltman: We don't know what's gonna happen yet, and we don't have a final draft yet, but we are watching it, and we are very hopeful that in the next year or so, we're gonna be able to be on one of these webinars.

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Jessica Waltman: And give you really good news, and say it's going to be a lot easier to give out documents and notices to your plan participants.

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Jessica Waltman: So, don't need to do anything yet.

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Jessica Waltman: just… Be excited!

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Jessica Waltman: And wait for more news. We will tell you when it happens.

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Jessica Waltman: Another new development…

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Jessica Waltman: That, again, not final yet, but is probably pretty exciting if it does get finalized, is the Trump administration has proposed a new type of employee benefit plan option, and that would be a plan option specific to fertility benefits.

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Jessica Waltman: And what they have proposed is actually an ERISA-exempt type of benefit plan. So that means many of the federal compliance requirements would not apply. So it wouldn't be subject to COBRA, the ACA, the No Surprises Act, none of that.

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Jessica Waltman: Now, it does come with some hitches. It would need to be distinct from the medical plan, or not a, essential part of the medical plan. It would have a lifetime limit of up to $120,000 combined. That would be indexed.

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Jessica Waltman: For inflation, because it would be allowed to have a lifetime limit, because it wasn't subject to the ACI.

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Jessica Waltman: And it would be limited to fertility benefits only. The definition, though, of fertility benefits that they've proposed is pretty wide, so it covers pretty much any type of assisted reproductive technology, like IVF,

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Jessica Waltman: Covers all the diagnoses, medical management, prescriptions, all of that, surgery, everything. So a very expansive definition.

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Jessica Waltman: And, if this does come… get finalized, we expect that these new fertility benefit plans will be on the market.

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Jessica Waltman: So right now, they've finished getting their comments on this rough draft, and they are working on polishing it up, and we're hoping that they're going to finalize it soon, and if they do, we will let you know, and certainly your consultants will let you know if this ultimately leads to new options on… in the marketplace.

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Jessica Waltman: Okay, couple more proposed rules awaiting finalization. These…

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Jessica Waltman: you also don't need to do anything with yet, because they're not final. And these two, really, even though they will impact group health plans when they are finalized, if they are finalized.

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Jessica Waltman: they… really, the work will not fall on the employer plan. It's going to fall on, your service providers, either your carriers or third-party administrators, if you're self-funded, or you're a PBM.

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Jessica Waltman: So, One goes back to 2025, so we've been waiting for this to be finalized.

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Jessica Waltman: For a while, and it's directed at those pharmacy benefit managers that run our prescription drug plans behind the scenes, and it would require them to, report their compensation to the group health plans, so the plan sponsors, like you.

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Jessica Waltman: Very similar to those compensation disclosures that NFP gives you every year, explaining our compensation before each plan renewal.

00:27:16.469 - 00:27:31.939
Jessica Waltman: So, that would give you much more transparency and give the whole market a greater understanding of how PBMs make their money. So that will be very interesting if it's finalized and how it's carried out. But it would really fall on the PBM to do it.

00:27:31.999 - 00:27:35.289
Jessica Waltman: And you all would be the recipients of the information.

00:27:35.659 - 00:27:45.299
Jessica Waltman: The second one also deals with price transparency. In the first iteration of the Trump administration, there were transparency and coverage rules.

00:27:45.299 - 00:28:03.339
Jessica Waltman: finalized, and they've been in effect for a number of years. And they are something that, while ultimately, especially if you're self-funded, the plan sponsor has responsibility for them, in reality, it is the carriers and the third-party administrators that are carrying it out.

00:28:03.349 - 00:28:15.959
Jessica Waltman: And this makes a bunch of technical changes to what they need to do for those things. And those rules deal with the, transparency displays.

00:28:15.959 - 00:28:27.949
Jessica Waltman: That people have when they go into their health plan portals, what kind of information they can see about cost estimates for benefits that they might get, and then also, health plans.

00:28:28.089 - 00:28:36.229
Jessica Waltman: And health carriers need to post de-identified claims data in machine-readable files online, so…

00:28:36.229 - 00:28:51.389
Jessica Waltman: So that very smart people can grab that data and analyze it and help us build cost control tools and data analytic tools. And so, there's some changes to how that information would need to be posted to try and make it easier

00:28:51.389 - 00:29:09.019
Jessica Waltman: and more usable. So if that happens, you may see it addressed in, you know, upcoming plan contracts or administrative service agreements with TPAs, but there's really probably very little the employer themselves is going to have to do. But we're keeping on top of it, and we'll let you know.

00:29:10.329 - 00:29:25.169
Jessica Waltman: So finally, in this segment, I'm going to just talk again about some legislative activity. Again, going back to what David told us, Congress, very divided, they are passing less legislation than typical.

00:29:25.269 - 00:29:41.659
Jessica Waltman: Because they have just such slim margins right now, so they really… it's very hard to get bills through. They do typically pass, some big bills each year, and we anticipate some big must-pass bills happening more towards the end of this year.

00:29:41.799 - 00:29:58.599
Jessica Waltman: And they have been discussing a lot of healthcare items this summer, this spring, that we think maybe some of these pieces could get into some of those must-pass bills at the end of the year. But we're just not really sure how that's going to shake out yet. We're just continuing to watch it.

00:29:58.599 - 00:30:06.199
Jessica Waltman: But the topics they're most currently discussing include affordability of healthcare, Price transparency.

00:30:06.239 - 00:30:15.759
Jessica Waltman: Some anti-competitive contract clauses, making sure that those don't happen, because they could limit plan design flexibility.

00:30:15.829 - 00:30:32.099
Jessica Waltman: Also, a few years ago, in 2021, they passed a law that really limited surprise medical bills at the federal level and created an independent dispute process where carriers and TPAs and providers kind of duke it out on the back end about pricing.

00:30:32.149 - 00:30:46.239
Jessica Waltman: That hasn't exactly turned out the way some people thought it would, and there's some concern that it's not really saving that much money, and there may be some abuses, so they're looking at some legislation to potentially, make some changes there.

00:30:46.239 - 00:30:55.019
Jessica Waltman: But all of those things may move forward as we get towards the end of the year and into a lame duck session. They may not.

00:30:55.149 - 00:31:10.889
Jessica Waltman: Another thing that is also being discussed at the federal level is paid leave, at the federal level, so I'm going to turn it over to our leave expert, David, so he can explain more about that, and then also state paid leave developments.

00:31:11.850 - 00:31:20.509
David Rotman: Yes, thank you, Jessica. So there has been a growing amount of activity at the federal legislative level involving

00:31:20.820 - 00:31:37.800
David Rotman: paid family and medical leave, although currently, initiatives are underway, there hasn't been any bill that has reached final enactment. But as you can see, there have been attempts in both the House and Senate to introduce legislation that would establish a nationalized system

00:31:37.850 - 00:31:50.379
David Rotman: for paid family medical leave, because most of the activity, again, has been at the state level. Creating a more federal system, would have big implications as far as what standards employers would have to follow.

00:31:50.380 - 00:32:02.960
David Rotman: But as I said, that is currently in its early stages, but we do anticipate, moving forward, especially into 2027, there are going to be a growing amount of legislative initiatives to address that issue.

00:32:03.380 - 00:32:09.329
David Rotman: So, moving on to individual state activity, There has been a…

00:32:09.810 - 00:32:24.369
David Rotman: flurry of legislative and regulatory activity involving paid family medical leave at the state level over the last year, and three of the newest states to implement paid family medical leave programs are Minnesota, Maryland, and Virginia.

00:32:24.910 - 00:32:27.380
David Rotman: So moving to the next slide.

00:32:27.540 - 00:32:36.570
David Rotman: Maryland, initially created a new PFML program through the Time to Care Act of 2022.

00:32:36.570 - 00:32:52.780
David Rotman: This, in turn, established the Family and Medical Leave Insurance Program, or FAMILI, as it's abbreviated. This program is administered through the State Department of Labor and established a state-managed program for private sector workers taking family medical leave.

00:32:53.620 - 00:33:12.160
David Rotman: The program itself was initially slated to begin employer payroll contributions in 2023. However, under a revised implementation timeline, payroll contributions are actually set to begin in January of 2027, and benefits are scheduled to begin in January of 2028.

00:33:12.710 - 00:33:21.289
David Rotman: The program itself will be funded through employer and employee payroll contributions, with the initial plan contribution rate set at 0.9%.

00:33:21.400 - 00:33:27.089
David Rotman: The law will apply to all employers with at least one employee working in the state.

00:33:27.200 - 00:33:35.460
David Rotman: However, only employees who have worked at least 680 hours during the previous four calendar corners will actually be eligible for benefits.

00:33:35.860 - 00:33:51.170
David Rotman: Now, with regards to the actual benefits, eligible employees can receive up to 12 weeks of paid leave for specific covered reasons. This includes things like caring for a family member or an employee's own illness, and benefits will be payable up to $1,000 per week.

00:33:51.970 - 00:34:11.779
David Rotman: With regards to specific key employer action items, this would include registering with the state and complying with employee notice requirements, and these notice requirements would include providing benefit notices before payroll deductions would begin, at higher, annually, and when leave may be qualifying.

00:34:12.159 - 00:34:20.790
David Rotman: Also, if an employer opts to sponsor a private PFMO plan, they must submit their declaration of Intent to the state by November 15th.

00:34:21.719 - 00:34:24.869
David Rotman: So, slide to Minnesota.

00:34:28.080 - 00:34:39.220
David Rotman: This… the state's Paid Family Medical Leave Program in Minnesota was enacted in May of 2023. It became fully operational on January of this year.

00:34:39.219 - 00:34:48.519
David Rotman: As with Maryland, the program provides eligible employees with job-protected leave and partial wage replacement for qualifying medical and family reasons.

00:34:48.750 - 00:35:00.220
David Rotman: However, unlike Maryland, eligibility for benefits is earnings-based and not hours-based, so there's no actual employee tenure or work requirement in order to qualify for benefits.

00:35:00.360 - 00:35:18.409
David Rotman: The paid leave program applies to nearly all private sector employers with at least one employee in Minnesota. Also, employers may choose to participate in the state plan or obtain approval for a private plan that provides benefits and protections equal to or greater than those available under the state plan.

00:35:18.920 - 00:35:26.180
David Rotman: And as with Maryland, eligible employees may receive up to 12 weeks of paid family and medical leave.

00:35:26.480 - 00:35:39.970
David Rotman: However, unlike some other PFML programs, the leave can actually be taken consecutively for both family and medical leave. So, for example, an employee can take up to 20 weeks of combined leave if they qualify for both family and medical leave.

00:35:40.730 - 00:35:59.899
David Rotman: The program is funded through employer and employee payroll contributions, as with Maryland and other PFML programs in other states. Covered employers must submit quarterly employee wage details and remit paid leave premiums. The first premium payments were actually due in April of 2026 of this year.

00:35:59.970 - 00:36:16.939
David Rotman: And, like Maryland, employers must comply with applicable employee notice requirements and hang a paid leave poster in a conspicuous location, and ensure that they're meeting, required notice distribution requirements at time of hire and at various points during the year.

00:36:17.840 - 00:36:20.040
David Rotman: Turning, finally, to Virginia.

00:36:22.050 - 00:36:46.620
David Rotman: Virginia is actually one of the newest states to adopt a statewide PFML program. This law was enacted in April of 2026. However, unlike Minnesota, which is already operational, and Maryland, which is in its final implementation period, Virginia remains in a regulatory build-out period, and we are anticipating additional guidance from the State Employment Commission over the next year.

00:36:47.330 - 00:36:54.570
David Rotman: Nonetheless, we can still provide a basic overview of the law's requirements based on the provisions outlined in the legislation itself.

00:36:55.090 - 00:37:00.909
David Rotman: Specifically, the law will apply to all private sector employers with at least one employee in the state.

00:37:01.150 - 00:37:09.860
David Rotman: There is no minimum employer… employee tenure or work period requirement, but an employee must be eligible for state unemployment insurance in order to be covered.

00:37:10.110 - 00:37:21.500
David Rotman: The employ… the program will be funded, as with the other two states, through payroll contributions assessed to both employers and employees. That will begin in April of 2028.

00:37:21.650 - 00:37:45.169
David Rotman: In terms of eligibility, the Virginia law is somewhat broader than FMLA or other state PFML programs. It applies to a broader array of individuals, including registered domestic partners, stepchildren, grandparents, grandchildren, and even certain individuals residing in an employee's household where there's an expectation of caregiving, but no actual family relationship.

00:37:46.650 - 00:37:56.709
David Rotman: With regards to benefits, eligible employees could receive up to 80% of their average weekly earnings, subject to certain statutory minimum and maximum limits.

00:37:57.040 - 00:38:10.500
David Rotman: And may receive up to 12 weeks of benefits per year. And as with Maryland and Minnesota, employers also have the option to apply for a private plan if it meets or exceeds the program's minimum requirements.

00:38:11.080 - 00:38:26.540
David Rotman: So as we're still in the early stages of the Virginia Law's implementation, it is critical that covered employers closely monitor agency rulemaking and guidance regarding this program, but we will continue to review and communicate any important updates as the program continues to be implemented.

00:38:27.750 - 00:38:43.440
David Rotman: And finally, summing it all up, for the last three states, all three states have a minimum coverage period of 12 weeks for paid family medical leave, with all states offering employers the opportunity to sponsor a private plan that meets specific requirements.

00:38:43.440 - 00:38:59.489
David Rotman: However, Minnesota is currently the only state that is fully operational for both employers and employees. I should also mention we have a number of excellent resources available regarding these and other state PFML programs, so please let us know if you have any additional questions.

00:38:59.590 - 00:39:07.439
David Rotman: Or, if you'd like to access our numerous lead publications for your own reference, please don't hesitate to reach out.

00:39:08.920 - 00:39:21.940
David Rotman: And then finally, moving on to pending or, tentative PFML programs at the state level, one in particular, Pennsylvania, has

00:39:22.920 - 00:39:30.990
David Rotman: begun its final stages of implementation. This involves a paid family medical leave bill.

00:39:30.990 - 00:39:44.750
David Rotman: that has passed the State House. It's currently under review in the State Senate. At this point, we don't have the full details of the law, and it is… because it's still being finalized, but the bill is called the Family Care Act.

00:39:44.750 - 00:40:02.639
David Rotman: And as with other states, it includes 12 weeks of paid family medical leave for eligible employees. We will continue to monitor its progress and provide updates if and when the bill is finalized and enacted, but this is certainly one that we are anticipating will reach full enactment at some point in the near future.

00:40:03.270 - 00:40:05.720
David Rotman: And with that, I'll turn it back over to you, Jessica.

00:40:08.680 - 00:40:25.329
Jessica Waltman: Thank you, David. Okay, I'm gonna… we're gonna stop talking about these policy developments now. We're gonna get a little bit more practical. Things that are, you know, some case studies and some examples, specifically related to eligibility and management of the plan.

00:40:25.750 - 00:40:33.530
Jessica Waltman: Eligibility really, really matters when you are a group health and welfare plan sponsor. It's…

00:40:33.870 - 00:40:47.669
Jessica Waltman: typically, even if you have a fully insured plan, or you have a self-funded or level-funded plan, the carrier, the TPA, puts eligibility policing on the employer.

00:40:47.870 - 00:41:05.180
Jessica Waltman: And employers have a fiduciary duty to follow their plan documents and their eligibility terms. And so, we see, sometimes, some… some little mess-ups here. And we want to just kind of go over with them with you, so we can talk about some

00:41:05.370 - 00:41:20.869
Jessica Waltman: Common mistakes, and really effective ways to prevent issues in the future that can not only reduce your compliance risk, but also really strengthen your plan administration and hopefully save costs for our plan sponsors.

00:41:21.000 - 00:41:40.030
Jessica Waltman: So, I'm gonna give 3 real-life examples. I've been doing benefit compliance for over 25 years, so these are real issues that I have dealt with time and time again in my career, including, you know, as frequently as this week we've dealt with some of these issues. So, they just keep coming up.

00:41:40.260 - 00:41:44.690
Jessica Waltman: So my first example is going to deal with

00:41:44.980 - 00:41:49.810
Jessica Waltman: when we extend leave instead of offering COPRA.

00:41:49.830 - 00:41:57.899
Jessica Waltman: So here's a typical situation. You have an employee who has a serious medical issue themselves.

00:41:57.900 - 00:42:10.320
Jessica Waltman: And they use their federal medical, family medical leave, they use any state leave that they have, but they just can't come back to work due to their ongoing medical issues.

00:42:10.320 - 00:42:22.319
Jessica Waltman: Now, the hope is that they will be able to come back to work, and the employer does not want to terminate this employee. They're not… they're just not ready, to stop working. They think that they can come back.

00:42:22.580 - 00:42:31.470
Jessica Waltman: However, and they're also not in a covered… this individual is not in a covered stability period when it comes to the ACA employer mandate. So.

00:42:31.810 - 00:42:38.399
Jessica Waltman: Technically, these individuals, because their protected leave that protects their access to benefits is up.

00:42:38.640 - 00:42:47.050
Jessica Waltman: They no longer qualify for the employee benefit plan, because they're not working enough hours, they're not actively at work.

00:42:47.270 - 00:42:54.039
Jessica Waltman: But what sometimes happens is the employer, the HR person, doesn't think to offer COBRA.

00:42:54.080 - 00:43:10.939
Jessica Waltman: Because they think they associate COBRAR with a termination, and they don't want to terminate the employee. So what they do is they maybe create, like, a separate kind of sleeve of absence, an extended leave, they just say you can be out for another few weeks, or a few months, and they keep them on the benefit plan.

00:43:11.560 - 00:43:13.389
Jessica Waltman: So why is this a problem?

00:43:13.720 - 00:43:17.080
Jessica Waltman: Well, first of all, as we already covered.

00:43:17.160 - 00:43:36.629
Jessica Waltman: the employer has the duty to the whole plan to follow the terms of the plan document, and follow those eligibility terms. And, you know, virtually every plan specifies that if you're not actively at work, that you cannot remain on the benefit plan, and you're not create… you know, there's hours of service if you're not on a protected leave.

00:43:36.670 - 00:43:44.759
Jessica Waltman: Or, other protected… situation, that if you're just on a non-protected leave.

00:43:45.020 - 00:43:49.369
Jessica Waltman: you're not working any hours, and you don't qualify.

00:43:49.570 - 00:43:57.299
Jessica Waltman: So, keeping them enrolled conflicts with the plan document. Also, in this particular case, I've seen this happen a few times.

00:43:57.310 - 00:44:12.660
Jessica Waltman: The person involved, the employee, has a serious medical condition. They may be applying for disability at the federal level, and they may actually qualify for an extension of COBRA due to that disability, if they were offered COBRA.

00:44:12.810 - 00:44:25.490
Jessica Waltman: But the COBRA offer timing matters when it comes to that disability, extension. So, by keeping the person on the benefit plan and not offering COBRA when they're supposed to.

00:44:25.590 - 00:44:30.460
Jessica Waltman: The employer can actually mess things up for that employee that they were trying to help.

00:44:30.530 - 00:44:41.730
Jessica Waltman: So, that is a very good reason to be very mindful of when, you need to offer COBRA due to reduction of hours. That would be the qualifying event.

00:44:41.730 - 00:44:52.150
Jessica Waltman: Also, if that individual had a high-cost claim, and they weren't eligible for the plan, the employer could become liable for those claims.

00:44:52.160 - 00:44:54.749
Jessica Waltman: So that's a lot of reasons to keep on top of that.

00:44:56.980 - 00:45:11.669
Jessica Waltman: Okay, here's another one related to life insurance. So, group plan sponsors are entirely responsible for admitting, you know, administering their group life benefits according to their plan document terms.

00:45:11.710 - 00:45:29.019
Jessica Waltman: So, if they're not eligible, the employer can be liable. So, in this type of case, again, seen this multiple times, there's an employee, or a group of employees, and maybe they're terminated. Maybe they're letting go of this division, or maybe just this person quits.

00:45:29.250 - 00:45:33.759
Jessica Waltman: And… They're an employee that was well-liked, they did a good job.

00:45:33.770 - 00:45:52.509
Jessica Waltman: and the HR person thinks, like, I might be able to rehire them, like, they might come back. We might be busy, we might need to bring them back, they might want to come back, maybe they have that conversation. So instead of fully terminating the person, even though the person has quit, they are not working, they have resigned, you have a letter of resignation, everything.

00:45:52.510 - 00:45:59.660
Jessica Waltman: Instead of fully terminating them in the Benefits Admin system, they put them in some other category, like inactive.

00:45:59.680 - 00:46:05.600
Jessica Waltman: So that it will be easier for them to rehire them, so they won't have to, like, redo a bunch of paperwork.

00:46:05.700 - 00:46:07.690
Jessica Waltman: If the business needs change.

00:46:08.160 - 00:46:27.290
Jessica Waltman: But what happens was, because the person was still employed, and they weren't keeping good track of who was on the group life plan, these individuals stay… the individual stays on the group life plan. And they didn't offer that individual their group life conversion notice to go to individual coverage, and they kept them on that policy.

00:46:27.450 - 00:46:34.080
Jessica Waltman: And then, you know, a few years pass by, and the person never returns back to the employer and dies.

00:46:34.430 - 00:46:50.529
Jessica Waltman: And there are beneficiaries are going through their stuff, and they see information about how they used to have group life benefits, they're looking for a conversion, they want to know, did it come into an individual policy? They go back to the employer, and they find out, oh, the person is still enrolled on the group life plan.

00:46:50.830 - 00:46:54.919
Jessica Waltman: And guess who is liable for that group life benefit, then?

00:46:55.060 - 00:47:05.580
Jessica Waltman: That death benefit, not the carrier, because that person wasn't really employed, and they never should have still been on the group life plan, so the company had to pay the death benefit.

00:47:06.850 - 00:47:10.539
Jessica Waltman: Okay, a final example, real life,

00:47:10.780 - 00:47:25.500
Jessica Waltman: say you have a well-liked employee. Everybody liked them, they have to leave working, maybe because they do have a medical issue. So they just, they decide to leave employment, they quit, they're working through their health stuff, and they elect COBRA.

00:47:25.710 - 00:47:31.280
Jessica Waltman: Because they want to keep their coverage. And they go through the entire 18 months of their COBRA period.

00:47:31.280 - 00:47:47.740
Jessica Waltman: And maybe because they're sick, or they're going through a lot, they kind of forget exactly when COBRA is supposed to end, so they schedule some surgery, they've got some stuff going on medically, and they realize that some of their medical procedures are scheduled and locked in for after COBRA is over.

00:47:47.900 - 00:47:57.149
Jessica Waltman: So they call HR, their friends there, and they say, hey, could we maybe get, like, I could maybe get, like, a couple of extra months on COBRA so that I can do my surgery?

00:47:57.390 - 00:47:59.059
Jessica Waltman: And the HR says yes.

00:47:59.470 - 00:48:10.410
Jessica Waltman: So why is this a problem? Well, first of all, COBRA runs at a fixed maximum period by law, and that's outlined in the plan documents, so we're creating a violation there.

00:48:10.410 - 00:48:24.119
Jessica Waltman: So extending it as a favor to someone is both, precedent-sending, they may probably are not doing that for everyone, and, it's not permitted under the plan documents. But again, also, this is a high-cost claimant.

00:48:24.230 - 00:48:42.419
Jessica Waltman: Perhaps it's a self-funded plan, and they've already hit their specific limit, and they're going to stop loss. Do you think the stop loss is going to pay that claim? No. No, they are not. It's going to go back to the employer. The stop loss carrier will be quite crude about it. So we've seen that happen many times.

00:48:42.730 - 00:48:53.940
Jessica Waltman: So, what do we do about it? I want to leave you, you know, just with all these horror stories. I want to give you some tips on how to mitigate the risks and solve these problems. So, here are some best practices for you.

00:48:54.470 - 00:48:56.440
Jessica Waltman: Okay, number 1.

00:48:56.590 - 00:49:04.719
Jessica Waltman: Prevention is the best medicine, and your best prevention is putting in place a comprehensive leave policy.

00:49:05.040 - 00:49:24.140
Jessica Waltman: And by this, I do not mean just something that addresses, you know, FMLA and paid leave. I mean a comprehensive policy that looks at your plan terms, looks at your eligibility, looks at how the employer mandate affects how you're counting hours, how you're determining coverage eligibility, looks at COBRA.

00:49:24.570 - 00:49:43.179
Jessica Waltman: All of these things. And it says, when you can join the health plan, when you leave the plan, what happens during a leave of absence, what different kinds of leaves of absence there might be, which ones are eligible for health benefits, which ones aren't, who pays what when.

00:49:43.180 - 00:49:45.470
Jessica Waltman: All of those things written out.

00:49:45.710 - 00:49:53.100
Jessica Waltman: Outlined in detail, available to the employee, available to the employer, applied consistently.

00:49:53.100 - 00:50:07.569
Jessica Waltman: And really looking at your policy terms, talking to your carrier, to your third-party administrator, to your stop-loss provider. If you're gonna offer, you know, leaves of absence, where you're gonna let people stay on.

00:50:07.660 - 00:50:21.109
Jessica Waltman: health benefits, maybe like a sabbatical or something like that. Is that alright with them? And then really spelling it out and making sure your plan document terms match what you've promised in any type of leave manual or employee policy.

00:50:21.660 - 00:50:39.159
Jessica Waltman: So that can really help you out and give you a roadmap to follow when you get into these tough situations, and it can also mitigate your risk in terms of litigation against the plan by plan participants, denied claims, other costs that the employer might need to absorb.

00:50:40.300 - 00:50:49.929
Jessica Waltman: Second thing, keeping all your plan eligibility rules in mind. And this is really important in general, like, whatever you spell out in terms of plan eligibility.

00:50:50.020 - 00:50:57.960
Jessica Waltman: But, specifically, I want to talk about the employer mandate and the ACA counting employee rules.

00:50:57.960 - 00:51:11.940
Jessica Waltman: So there's kind of two ways to do that and offer coverage to eligible employees. Many employers use a monthly measurement period. That's particularly common if you have a very stable workforce. Everybody works 9 to 5, 40, you know, 35, 40 hours a week.

00:51:11.970 - 00:51:20.939
Jessica Waltman: But those with variable hour employees, and even just sometimes other employers with stable workforces, use what's called a look-back stability period.

00:51:20.940 - 00:51:37.519
Jessica Waltman: So we measure employee hours over the course of typically a year, sometimes it's a little bit less, but typically a year. And then, people that meet that coverage standard get offered coverage for the whole next stability period, which, again, is usually a year.

00:51:37.520 - 00:51:46.920
Jessica Waltman: And even if, as long as that person isn't terminated, when they're in their stability period, even if they only go down to a few hours a week, or no hours a week.

00:51:46.920 - 00:52:01.389
Jessica Waltman: they still have coverage. So if someone's in the stability period, in that first example, if they had been in a stability period, you wouldn't have offered COPRA until the stability period ends. But if they are, you keep that coverage

00:52:01.410 - 00:52:10.060
Jessica Waltman: in place. If they're not, and you don't have a stability period, then you would offer COBRA when they stop meeting that active at work standard.

00:52:10.060 - 00:52:20.569
Jessica Waltman: And the other thing is just keeping in mind that, you know, we're counting hours of service correctly. If someone is on a paid leave, if they're on a protected leave, like FMLA,

00:52:20.570 - 00:52:32.980
Jessica Waltman: USRA leave if they're called up to active military duty. Those, hours of service count towards working with the employer mandate. And then unpaid leave often does not.

00:52:32.980 - 00:52:41.770
Jessica Waltman: So you're going to want to make sure you stay mindful of those rules, and any particular nuances with state laws, state leave, and how you track hours.

00:52:43.480 - 00:52:46.480
Jessica Waltman: Okay, now this is probably obvious.

00:52:46.620 - 00:53:00.170
Jessica Waltman: But also, we know that employees will ask for the moon. So, when employees ask for one-off exceptions, or you think, oh, maybe I should give a one-off exception to, like, the CEO or something like that.

00:53:00.220 - 00:53:12.520
Jessica Waltman: Think again. We do not want to make one-off exceptions for eligibility terms, or really any plan document terms, because that can carry legal and financial consequences.

00:53:13.020 - 00:53:27.799
Jessica Waltman: Ask the fiduciaries of the health plan, you are not only responsible for following the plan document, but you have to act in the overall best interest of the plan. Overall best interest of the plan and the plan participants is not

00:53:27.900 - 00:53:37.900
Jessica Waltman: at the best interest of one person. So you have to look at that as a whole. So you want to make sure you're upholding your ERISA fiduciary duties and your duty, to the plan participants.

00:53:38.150 - 00:53:39.320
Jessica Waltman: Also.

00:53:39.390 - 00:53:56.339
Jessica Waltman: If you make an exception for one person, you, again, could have discrimination exposure, and you can have claims exposure. Because if you are letting someone stay on the plan or join the plan when they're not supposed to, they could…

00:53:56.400 - 00:54:00.520
Jessica Waltman: If they have a high-cost claim, you could be on the hook for it.

00:54:00.530 - 00:54:14.399
Jessica Waltman: And also, it's not even if there's a high-cost claim. If a carrier or a stop-loss insurer does an eligibility audit, and they find people on there who were ineligible for the plan, and they've been paying claims.

00:54:14.400 - 00:54:25.620
Jessica Waltman: that could be a problem well, too. And it's particularly an issue for anybody who offers a self-insured plan, or a level-funded plan is still a self-insured plan for these purposes.

00:54:26.870 - 00:54:43.289
Jessica Waltman: And then finally, really confirming your eligibility terms with your carriers. So I talked a little bit about this when I was discussing the leave policy, but even if you don't have one, if you are unsure about eligibility, if you… maybe there was a mistake made, and you're…

00:54:43.290 - 00:54:55.600
Jessica Waltman: putting somebody on the plan because there was, like, maybe an administrative error or some other reason. Any eligibility variance that you make, you're going to want to clear that with your carrier.

00:54:55.840 - 00:55:14.319
Jessica Waltman: And if you're self-funded or level-funded, not only are you going to bring it up to the TPA, but I can't stress this enough, you can't rely on the third-party administrator to tell the stop loss insurer. You need to make sure the stop loss insurer knows distinctly, so you need to reach out to them.

00:55:14.320 - 00:55:27.850
Jessica Waltman: Because if you have a mismatch there, and they don't know, and they think that you've let somebody on that shouldn't, and they haven't approved it, again, that can result in problems in the coverage.

00:55:27.850 - 00:55:42.349
Jessica Waltman: But if you get written approval, then you're going to have, you know, the ability to know that those claims are going to be paid. And then you're also going to be able to know how you do that for other similarly situated employees.

00:55:42.350 - 00:56:00.330
Jessica Waltman: Because we're not going to make one-off exceptions for people. When we come to eligibility, we have to treat all similarly situated employees the same. Otherwise, again, you have a compliance risk, you have a non-discrimination risk, and again, you can have legal and financial risks.

00:56:00.420 - 00:56:10.249
Jessica Waltman: And just, to remind you, most stop-loss carriers use a mirroring policy. So they take your plan document, they've got a copy of it, and they are

00:56:10.330 - 00:56:26.539
Jessica Waltman: covering based on what the plan document says. So you're going to really want to make sure that your leave policy and any of your procedures match that plan document, and that they're okay with any variance, because again, they could very easily deny a claim.

00:56:28.340 - 00:56:37.609
Jessica Waltman: Okay, so now I'm going to flip it back to David to just wrap things up and talk about, some of our takeaways and NFP-relevant resources.

00:56:38.950 - 00:56:51.340
David Rotman: Yes, and thank you, Jessica. And so, just to quickly recap, the upcoming midterm elections may have a direct impact on the healthcare agenda of the 120th Congress, as both parties have pledged to make healthcare and tax policy a priority.

00:56:51.470 - 00:57:03.299
David Rotman: At the federal level, as Jessica discussed, the new DCAP rules are now in effect. And employers should also monitor paid family medical leave developments at the state level as we move into the second half of 2026.

00:57:03.590 - 00:57:11.470
David Rotman: Employers should also pay close attention to plan eligibility terms and avoid issues like one-off exceptions, as Jessica was just describing.

00:57:12.610 - 00:57:28.480
David Rotman: With regards to resources, please also make use of our publications and resources on the topics we discussed today and other compliance topics. We have some excellent materials on topics like paid family medical leave, DCAP requirements, and a risk fiduciary guidelines.

00:57:28.550 - 00:57:33.470
David Rotman: You may also contact your broker or consultant for copies of these materials if you so wish.

00:57:33.790 - 00:57:36.129
David Rotman: And with that, I'll turn it back over to you, Amber.

00:57:41.130 - 00:57:46.879
Amber Posthauer: All right. Well, thank you, Jessica and David, for sharing your valuable time and expertise with us today.

00:57:46.960 - 00:58:01.950
Amber Posthauer: To reiterate, today's presentation was recorded. We'll be sharing the recording in the follow-up email and on the NFP website. If there are any portions of this call that you missed by Monday, you'll receive an email with a link to the full recording. The PowerPoint slides used during this presentation will be shared in the same email.

00:58:02.240 - 00:58:13.369
Amber Posthauer: At the end of this call, a survey will populate in a new window. Please take a brief moment to complete the survey, as it lets us know what topics are important to our listeners, and helps make our education program as current and relevant as possible.

00:58:13.540 - 00:58:18.460
Amber Posthauer: That concludes our webinar for today. Thank you, everyone, for joining us, and have a great day!