The Medicare Modernization Act requires employers that provide prescription drug coverage to Medicare-eligible individuals to complete the Online Disclosure Form to the U.S. Centers for Medicare & Medicaid Services (CMS) to report whether such coverage is creditable prescription drug coverage (“creditable coverage”). Creditable coverage is coverage that is expected to pay, on average, as much…
The U.S. Department of Labor (DOL) has extended the effective dates of its model Employer CHIP Notice, General Notice of COBRA Rights, and COBRA Election Notice through December 31, 2019. Previously, these model notices expired on December 31, 2016. No other changes have been made to these notices. For the latest guidance regarding these notices,…
The U.S. Department of Labor (DOL) has published a final rule adjusting for inflation the civil monetary penalties assessed for violations of a number of federal labor laws. The increases generally apply to civil penalties assessed after January 13, 2017, whose associated violations occurred after November 2, 2015. Key Penalty Increases Penalty increases that may…
President Trump has signed an executive order calling upon federal administrative agencies to minimize the economic burden of the Affordable Care Act (ACA), pending repeal of the law. Until further guidance is issued or legislation is signed, however, all ACA requirements remain in effect, including penalties for noncompliance. In addition to making clear that the…
