IRS Maintains Health FSA Contribution Limit for 2021, Adjusts Other Benefit Limits

Posted on October 27th, 2020

On October 26, 2020, the Internal Revenue Service (IRS) released Revenue Procedure 2020-45, which maintains the health flexible spending account (FSA) salary reduction contribution limit from 2020, which is $2,750, for plan years beginning in 2021. Thus, for health FSAs with a carryover feature, the maximum carryover amount is $550 (20% of the $2,750 salary reduction limit) for plan years beginning or ending in 2021. The Revenue Procedure also contains the cost-of-living adjustments that apply to dollar limitations in certain sections of the Internal Revenue Code. 

Qualified Commuter Parking and Mass Transit Pass Monthly Limit Increase

For 2021, the monthly limits for qualified parking and mass transit are $270 each (which remain the same from 2020).

Adoption Assistance Tax Credit Increase

For 2021, the credit allowed for adoption of a child is $14,440 (up $100 from 2020). The credit begins to phase out for taxpayers with modified adjusted gross income in excess of $216,660 (up $2,140 from 2020) and is completely phased out for taxpayers with modified adjusted gross income of $256,660 or more (up $2,140 from 2020).

Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) Increase

For 2021, reimbursements under a QSEHRA cannot exceed $5,300 (single) / $10,700 (family), an increase of $50 (single) / $100 (family) from 2020.

Reminder: 2021 HSA Contribution Limits and HDHP Deductible and Out-of-Pocket Limits

Earlier this year, the IRS announced the inflation adjusted amounts for HSAs and high deductible health plans (HDHPs).

The ACA’s out-of-pocket limits for in-network essential health benefits have also increased for 2021.  Note that all non-grandfathered group health plans must contain an embedded individual out-of-pocket limit if the family out-of-pocket limit is above $8,550 (2021 plan years).  Exceptions to the ACA’s out-of-pocket limit rule are also available for certain small group plans eligible for transition relief (referred to as “Grandmothered” plans).  Unless extended, relief for Grandmothered plans ends December 31, 2021.

ACA Reporting Penalties (Forms 1094-B, 1095-B, 1094-C, 1095-C)

The table below describes late filing penalties for ACA reporting.  The 2021 penalty is for returns filed in 2021 for calendar year 2020, and the 2022 penalty is for returns filed in 2022 for calendar year 2021.  Note that failure to issue a Form 1095-C when required may result in two penalties, as the IRS and the employee are each entitled to receive a copy.

————————————————————————————————————————-

Wellbeing Resource: On-Demand Fair Recordings, Workplace Belonging and 2021 Food Trends

Posted on October 26th, 2020

I hope you all had a wonderful weekend!  Below please find this week’s curated list of wellbeing resources.  Feel free to share these resources, as appropriate, with your team. Have a safe and healthy week!

Alera Virtual Wellbeing Fair

• On-Demand Recordings – If you missed some of the sessions from our Alera Group 2020 Virtual Wellbeing Fair, there is still time to access this great content!  An amazing array of experts shared their insight on supporting our children through uncertain times, managing our finances during the pandemic, playing to your strengths at work, managing burnout and more!  Please take advantage of these wonderful events!

Career Wellbeing

• Cultivating Belonging in the Workplace – Uncertainty and instability often give rise to conflict and a feeling of separation. In this webinar, renowned mindfulness teacher Jack Kornfield will show us how we can bring forgiveness and compassion to our work relationships and navigate difficult situations skillfully.  Thursday, October 29th at 12PM ET.

Social & Family Wellbeing

• How to explain anything to anyone: 4 steps to clearer communication – Have you ever been talking to someone and see that they checked out?  Here are some tips to help you be able to explain pretty much anything to anyone more effectively. 

Financial Wellbeing

• 5 Signs You Need A Money Cleanse – Cleanses are a great way to hit reset on certain areas of your life. They help you break bad habits, flush toxins, and set yourself up with a powerful plan for the future. A 30-Day Money Cleanse is no different than any other cleanse – except that it hits reset on your money.

Physical Wellbeing

• The 10 Biggest Health Food Trends of 2021, According to Whole Foods Market – For the 6th year in a row, Whole Foods Market has released its annual Top 10 Food Trends list, and in 2021, we can expect to see a lot of fancy basics, innovative oils, plenty of chickpeas, and more. This article reveals the top food trends that are about to take over grocery shelves and pantries nationwide.
• How to Methodically Increase Your Walking Speed – If you are looking to accomplish more work in the same amount of time, this article will give you some pointers on how to improve your walking speed in a practical and thoughtful way.

Emotional Wellbeing

• This Election Season, It’s Going to Take More Than Deep Breaths – This article from Ginger.io discusses how to deal with the 3 most common election stressors; navigating difficult conversations with loved ones, dealing with uncertainty and concern for the future, and feeling generally overwhelmed. 
• Emotional Resilience – Famed mindfulness teacher Tara Brach will speak on emotional resilience, lead a practice using the RAIN (Recognize, Allow, Investigate, Nurture) method, and discusses how to avoid being hijacked by stressful stimuli. Scroll down the page to watch the recording at your leisure. 

Community Wellbeing

• Rock the Vote Volunteer Opportunities – Rock the Vote focuses on registering, educating and turning out young people to vote.  See their ‘Get Involved’ page to see how you can help. 

Employer Focused Wellbeing

• 11 Secrets from Top Talent Leaders: How to Increase Employee Engagement, Trust, and Belonging During COVID-19/Remote Work – PwC reported 54% of CFOs now plan to make remote work a permanent option.  Loneliness is currently one of the top reported problems from remote workers.  In this article, top talent leaders from Fortune 1000 companies share their top tips for employee engagement, trust and belonging in the Age of Remote. 

The Five Ws, and One H of Affordable Care Act (ACA) Measurement Methods

Posted on October 21st, 2020

This is the ninth article in our Compliance 101 blog series where we use six questions to break down important compliance topics. Below you will learn more about the Affordable Care Act (ACA) Measurement Methods. Read more below! Download this article.
 

Who needs to worry about measurement periods?   

• The IRS requires all applicable large employers (ALEs), including nonprofit, and government employers to report to the IRS whether they offered minimum value (MV), affordable coverage to its full-time employees (defined as, for a calendar month, an employee employed on average at least 30 hours of service per week, or 130 hours of service per month) to avoid a penalty, also known as an employer shared responsibility payment or “play or pay” rules.
• Non-ALEs are not subject to the employer shared responsibility regulations.

Definition: 
ALE, as defined in section 4980H(c)(2) of the Internal Revenue Code, enacted by the Affordable Care Act (ACA), with respect to a calendar year, is an employer that employed an average of at least 50 full-time or full-time equivalent employees on business days during the preceding calendar year.

What is the purpose of Measurement Methods?  

• The measurement methods provide minimum standard requirements for the identification of full-time employees as defined by the ACA.
• Two measurement methods are available for an ALE to determine which employees are full-time for ACA employer shared responsibility purposes
• Monthly measurement method (MMM)– the employer determines if an employee is a full-time employee on a month-by-month basis by looking at whether the employee has at least 130 hours of service for each month.
• Look-back measurement method (LBMM)  – an employee’s full-time status during what is referred to as the stability period, is based on their hours of service averaged over a proceeding period, which is referred to as the measurement period.
• All employees of an ALE must be tracked under one of these two measurement methods, the method and the hours worked during the year will dictate how to handle special circumstances that arise during an employee’s tenure, such as a reduction in hours, an unpaid leave, and more. Employers cannot track just
  one population of employees whose hours are more variable, rather, all employees must be tracked at all times under one of the two methods.
• Employers may always treat additional employees as eligible for coverage, or otherwise offer coverage more expansively than would be required to avoid an assessable payment under section 4980H, subject to compliance with any nondiscrimination or other applicable requirements.

Definitions:

What is an hour of service? 

• Each hour for which an employee is paid, or entitled to payment, for the performance of duties for the employer, and
• Each hour for which an employee is paid, or entitled to payment by the employer for a period of time during which no duties are performed due to vacation, holiday, illness, incapacity (including disability), layoff, jury duty, military duty or leave of absence.
• See FAQs 22-28 for information on exclusions and special circumstances. 

Key LBMM Terms: 

• Measurement period – a length of time for counting hours of service. (i.e. standard measurement period 
• (SMP) for ongoing employees & initial measurement period (IMP) for new hires.)
• Administrative period – a period of time to enroll/disenroll employees on employer health coverage.  
• Stability period –the length of time (typically the plan year) an employee’s status of full-time or part-time (under the ACA’s definition) is maintained based on their average hours measured in the prior measurement period. e.g. if an employee measured full-time during the measurement period they are treated as full time under the ACA and entitled to employer health coverage during the entire stability period regardless of the current number of hours they are working, including if their hours are reduced to zero during a furlough. 

Where may an employer use different measurement methods?   

•    In general, the same measurement method (or measurement periods) must be used for the same category of employee. For example, if the look back-back method is used for variable hour employees than all hourly employees must be measured by the look-back method.

• The regulations only permit an employer to use different measurement methods based on the following categories of employees:
  • Salaried and hourly employees
  • Employees whose primary places of employment are in different states
  • Collectively bargained and non-collectively bargained employees
  • Each group of collectively bargained employees covered by a separate bargaining agreement
• Different applicable large employer entities of the same applicable large employer (i.e. controlled group) may also use different measurement periods.

When an employee is on an unpaid leave of absence, what happens to their hours under the LBBM?

• “Unpaid special leave”: If an employee is on “unpaid special leave” as defined in the final regulations (i.e. FMLA, USERRA, Jury Duty), whose break in service is less than 13 consecutive weeks (26 weeks for an educational organization) the employer must either:
  • Treat the employee as credited with hours of service for any periods of special unpaid leave during that measurement period at a rate equal to the average weekly rate at which the employee was credited with hours of service during the weeks in the measurement period that are not part of a period of special unpaid leave.
  • Determine the employee's average hours of service for a measurement period by computing the average after excluding any special unpaid leave during that measurement period and by using that average as the average for the entire measurement period.
  • If the employee returns from a special leave of absence that is longer than 13 consecutive weeks
    • (26 weeks for an educational organization) the employer may treat the employee as a “new” hire and the employee’s eligibility for employer health benefits is determined in the same manner as any other new employee.
• Unpaid Leave of Absence: If an employee is on an unpaid leave of absence (e.g. furloughed, unpaid sabbatical or personal leave) the employee will generally will remain eligible for coverage during the remainder of the stability period, however, their leave of absence may impact the calculation of hours of service for the existing measurement period.  In general, an employer does not have to credit any hours of service for an employee on an unpaid leave of absence, therefore, it is possible the employee will fail to average 130 hours a month and no longer be deemed full-time for the subsequent stability period.
  • NOTE: If an employer wishes to not have employees lose eligibility due to the lack of hours while furloughed due to COVID-19, it is possible for an employer to amend their plan to exclude from consideration the dates during which an employee was involuntarily furloughed as a result of the 2019 Novel Coronavirus Public Health Emergency.

Why would an employer choose one measurement method over the other?

• The monthly measurement method is generally used by employers with a salaried workforce or a workforce whose schedules do not vary. Otherwise, employees whose schedules vary could gain or lose eligibility on a monthly basis to employer sponsored health coverage.
• The look-back measurement method is generally used by employers with a workforce whose employee’s schedules vary or hours fluctuate.  This method generally involves using an employee’s average hours of service per week during a period (referred to as a measurement period) to determine if an employee is a full-time employee under the ACA’s definition, during a subsequent period (referred to as a stability period). This allows employees with varying schedules to have a stable eligibility status for a consistent period of time (the stability period) on an annual basis.

How are measurement methods used for variable hour, seasonal employees, part-time employees, interns or temporary employees?

Definitions: 

• Variable hour employee –a newly hired employee whose hours of service vary significantly (e.g. hospitality, retail) so an employer is unable to determine at the start date whether the employee is reasonably expected to be employed on average at least 30 hours of service per week.  After completion of a standard measurement period, the employee is no longer a variable hour employee, rather they are classified as either full-time or part-time depending on the measurement results. 
• Seasonal employee – “an employee who is hired into a position for which the customary annual employment is six months or less, that by the nature of the position an employee in this position typically works for a period of six months or less, and that period should begin each calendar year in approximately the same part of the year, such as summer or winter” (e.g. a ski lift operator).
   
• In general, under the ACA, if the employees are hired with the intent to work 30 or more hours a week on average, then they are full-time employees even if their employment is temporary.
  • Interns or temporary employees: The ACA does not recognize “interns” nor “temps”. Rather the only ACA categories for
    • a W-2 employee are: full time, part-time, variable hour or seasonal. Thus, any intern or temporary employee working 30+ hours a week on average, an employer would need to offer coverage after the applicable waiting period but no later than the 91st day of employment to avoid potential penalties.
  • Newly hired variable hour & seasonal employees: The ACA provides a different set of rules under the look-back method for newly hired variable hour and seasonal employees. These employees will have his or her status as a full-time employee determined after an initial measurement period.
    • ALEs are allowed to use an initial measurement period (IMP) between at least three but no more than 12 consecutive months, to determine whether a newly hired variable hour or seasonal employee is a full-time employee.
    • If an employee averages at least 30 hours a week during the IMP, they must be treated as full-time for the subsequent stability period, which cannot be shorter than the IMP and must be at least six consecutive calendar months.
      • An ALE is not exposed to a shared responsibility penalty for an employee who averages at least 30 hours a week during the IMP if coverage is offered during the subsequent stability period.
    • If the employee does not average at least 30 hours a week during the IMP, the employer may treat the employee as part-time during the subsequent stability period, which cannot be longer than the measurement period used for other employees, nor can it be more than one month longer than the employee’s IMP.
  • Coverage must take effect for all variable hour employees who measure full-time, no later than the first day of the first calendar month after the employee's first anniversary with the employer (or roughly 13 months after the employee's date of hire).

Download this article.

NOTE: No guidance has been released that changes any of the ACA “play or pay” requirements for purposes of COVID-19.  The general rules as of this blog date (10/15/2020) are still applicable and employers should ensure they are in compliance with the ACA employer mandate to avoid penalties

Disclaimer: This blog was written by Michelle Turner, MBA, CEBS, Compliance Consultant, Alera Group Central Region. This blog post intends to provide general information regarding the status of, and/or potential concerns related to, current employer HR & benefits issues. This blog should not be construed as, nor is it intended to provide, legal advice. The opinions expressed herein are based upon the author’s experience as a Compliance Consultant and may not reflect the opinions of your counsel. 

The information contained herein should be understood to be general insurance brokerage information only and does not constitute advice for any particular situation or fact pattern and cannot be relied upon as such. Statements concerning financial, regulatory or legal matters are based on general observations as an insurance broker and may not be relied upon as financial, regulatory or legal advice. This document is owned by Alera Group, Inc., and its contents may not be reproduced, in whole or in part, without the written permission of Alera Group, Inc.

This article was last reviewed and up to date as of 10/15/2020.
4

Weekly Wellbeing Resources: Election Stress, Student Debt Management, & Employee Recognition

Posted on October 19th, 2020

The Alera Virtual Wellbeing Fair starts today! We hope you and your employees can join us!  Each day there are fitness breaks, mindfulness sessions, and a wide variety of Wellbeing breakout sessions.  Key sessions and registration links are noted below.  I am attaching some communications pieces you can use to let your employees know about the event.  If you have any questions, please don’t hesitate to reach out to me.

Have a safe and healthy week!

Career Wellbeing

• Kick Butt at Work: Play to Your Strengths – Do you go to work wanting to kick butt and win? Do you want to be engaged, productive and energized? Learn what drives Career Well-Being and what you can do by understanding the goals of your role, knowing your superpowers and recognizing your motivating needs. You may not be able to control what gets thrown at you, but you can manage how you respond.  Wednesday, October 21st  at 3 PM ET.

Social & Family Wellbeing

• Child and Teen Mental Health – Supporting Our Children (and Ourselves) Through Uncertain Times – Understand the primary challenges our children and teens are facing right now and walk away with a deeper understanding of what our children need most at this time to support their mental health. Monday, October 19th at 2 PM ET.
• The Connection between Recognition and Social Wellbeing –  In a world where our social nature as humans is drastically impacted by requirements to maintain 6 feet apart and working from home, we often forget the value of social connectedness. Learn how to rebuild that social connection and forge supportive relationships by recognizing the strengths in others.  Thursday, October 22nd at 3 PM ET. 

Financial Wellbeing

• Practical Planning for Uncertain Times –  Join award-winning comedian and financial mind Pete Dunn (aka Pete the Planner) as he discusses how to find financial stability. Pete will help you evaluate your current monetary status and offer tips for safeguarding your financial future (whatever that future brings)  Tuesday, October 20th at 2 PM ET. 
• How to Manage Student Loan Debt – Do you have questions about student loans? Maybe you're paying them off, or maybe you have a student about to enter college. Join Tuition.io as they talk about types of student loans and things you should know to help choose the best financial aid and repayment options for you.  Tuesday, October 20th at 3 PM ET. 

Physical Wellbeing

• Pain-Free in the Real World: 5 Key Facts About the Body’s Design – Are you tired of that nagging backache or shoulder pain? Do you have pain radiating into our leg? Does it take a while to “loosen up” after sitting or sleeping? Learn innovative solutions to your pain problems, it begins with understanding the 5 key facts about your body's design. Tune in and take part in this interactive 1-hour webinar designed to help you move better and feel better. As part of this session, you will receive a copy of the MoveWell® Daily Dozen, twelve bodyweight-oriented exercises. Wednesday, October 21st at 2 PM ET.
• Understanding Why What We Eat Matters – How does our diet impact COVID-19? What does proper nutrition look like?  How can proper nutrition reverse metabolic syndrome?  Join Zillion for this discussion on Thursday, October 22nd at 2 PM ET. 
• Ergonomics and the Perfect Day – Employees walk through their typical workday and learn innovative ways to set up their desks and workstations, stay hydrated, and access in-office and mobile stretch and reset videos to ensure healthy breaks throughout their workday.  Friday, October 23rd at 3 PM ET.
• Daily 15 Minute Fitness Breaks – Join Burnalong for a series of 15-minute fitness breaks all week long.  Monday: No More Tech Neck, Tuesday: Cardio Blast, Wednesday: Office Workout, Thursday: Standing Abs, Friday: Get Your Dance On.  12 PM ET Daily, October 19-23. 

Emotional Wellbeing

• Managing Stress and Burnout – We know that 2020 has added stress to all our lives. Dr. Myra Altman from Modern Health gives us some tips and tricks on how to effectively manage and mitigate stress and burnout while at the workplace.  Friday, October 23rd at 2 PM ET.
• 5 Powerful Life Lessons From a 2 Time Olympic Medalist – Join 2-time Olympic medalist, Shannon Bahrke, as she shares with us 5 powerful life lessons of how to get through these scary and uncertain times to shine our brightest self and be proud of what we can accomplish when pushed to the limit.  Monday, October 19th at 3 PM ET. 
• Daily Stillness Series – Join Namaste Wellness for a series of 15-minute mindfulness breaks all week long.  Monday: Mindfulness & Meditation, Tuesday: Neck & Shoulder Chair Yoga, Wednesday: Breathwork to Cultivate Calm, Thursday: Guided Relaxation, Friday: Mindfulness Meditation.  12:40 PM ET Daily, October 19-23. 

Employer Focused Wellbeing

• Help Your Employees Navigate Election Stress – Join Lyra on October 20th as Endeavor's CHRO, Kerry Chandler, talks about her experiences navigating election stress within various organizations and discusses tactics HR and benefits leaders can leverage to support their teams now through November 3rd. 
• Using Mindfulness and Performance Management During Time of Change – Join Headspace and Reflektive to learn how to best navigate corporate shifts with mindfulness and performance programs.  You will learn the latest research on performance management and mindfulness, how to leverage mindfulness and performance programs during times of uncertainty, tips for managing a remote workforce, and more.  Wednesday, October 21st at 1 PM ET.

Alera Group Acquires Gordon Atlantic Insurance Agency

Posted on October 15th, 2020

Alera Group, a national employee benefits, property and casualty, retirement services and wealth management firm, announced today that it has acquired Gordon Atlantic Insurance Agency, effective October 1, 2020.

Located in Norwell, Massachusetts, Gordon Atlantic works with clients throughout the Northeast to meet personal and business insurance needs.  Motivated by their motto of “Making Insurance Make Sense,” the Gordon Atlantic team has helped clients throughout the region by creating custom insurance programs that provide both clarity and coverage.

“As we continue to grow in the Northeast, we are thrilled to have Gordon Atlantic as an Alera Group company,” said Alan Levitz, CEO of Alera Group. “Their decades of industry expertise will be a valuable addition to our expanding presence in the greater Boston area. We are proud to welcome them to Alera Group.”

“At Gordon Atlantic, we take great pride in providing our clients with the best possible insurance solutions for their needs. As an Alera Group company, we are strategically positioned to continue to grow and meet our clients’ needs with industry-leading resources,” said Geoffrey Gordon, Managing Partner of Gordan Atlantic. “We look forward to the collaborative future ahead as part of Alera Group.”

Gordon Atlantic joins Alera Group through local firm Sylvia Group. The Gordon Atlantic team will continue serving clients in their existing roles. Terms of the transaction were not disclosed.

###

About Alera Group

Based in Deerfield, IL, Alera Group’s over 2,000 employees serve thousands of clients nationally in employee benefits, property and casualty, retirement services and wealth management. Alera Group is the 11th largest privately held firm in the country. For more information, visit www.jmjwebconsulting.com or follow Alera Group on Twitter: @AleraGroupUS.

Whitepaper: Changing an ERISA Plan Year

Posted on October 14th, 2020

There is nothing preventing an insurance contract/policy year to be longer than 12 months, it is, however, impermissible under ERISA, ACA and the Internal Revenue Code to have the plan year longer than 12 months. Therefore, when an employer extends their insurance policy (e.g. 13-month rate guarantee) or changes their renewal date (e.g. mid-year carrier change) if they also are considering changing their ERISA plan year to keep it consistent with their policy renewal date, there are compliance issues to consider.  

Download our whitepaper to learn more.

If you have any questions, please reach out to your local advisor or email us at info@aleragroup.com. 

Disclaimer: This blog was written by Michelle Turner, MBA, CEBS, Compliance Consultant, Alera Group Central Region. This blog post intends to provide general information regarding the status of, and/or potential concerns related to, current employer HR & benefits issues. This blog should not be construed as, nor is it intended to provide, legal advice. The opinions expressed herein are based upon the author’s experience as a Compliance Consultant and may not reflect the opinions of your counsel.

The information contained herein should be understood to be general insurance brokerage information only and does not constitute advice for any particular situation or fact pattern and cannot be relied upon as such. Statements concerning financial, regulatory or legal matters are based on general observations as an insurance broker and may not be relied upon as financial, regulatory or legal advice. This document is owned by Alera Group, Inc., and its contents may not be reproduced, in whole or in part, without the written permission of Alera Group, Inc.

This article was last reviewed and up to date as of 10/13/2020.

Alera Group Appoints John Mollica as Vice President, Business Intelligence and Transformation

Posted on October 13th, 2020

Alera Group today announced that John Mollica has been appointed as Vice President, Business Intelligence and Transformation, effective October 12, 2020. Mollica will be responsible for overseeing Alera Group’s data and analytics strategy across the United States.

Mollica is an accomplished executive with over 20 years of experience in Financial Services, most recently serving as Head of Product and General Manager of RiskMatch, Inc., a subsidiary of Vertafore, Inc. He has a unique combination of financial, business intelligence, data analytics and business transformation experience, which he will leverage while supporting the national data and analytics strategy for Alera Group.

“We are incredibly excited to welcome John to the Alera Group team, and the experience he brings in leading the strategic deployment and execution of data and analytical solutions to progressive insurance intermediaries,” said Billy Corrigan, Chief Operating Officer of Alera Group. “John’s combination of leadership skills, InsurTech knowledge and financial acumen will be instrumental in helping Alera Group continue its growth trajectory for the foreseeable future.”

“As Vice President, Business Intelligence and Transformation of Alera Group, I look forward to working closely with the leadership team to strengthen the company’s ability to harness the power of its underlying data sources. Through this, we will provide data-backed insight to our firms that will fuel continued growth and transformation,” said Mollica. “I have had the opportunity to work closely with the Alera Group team over the past three years, and have been hugely impressed with the progress they have made in a short time, and the quality of the brand it has already established. I look forward to working collaboratively with our sales teams, business line Practice Leaders and shared services teams to support our ongoing growth.”

Mollica will be based out of Norwalk, Connecticut. He joins Alera Group as the latest member of an industry-leading team of professionals across the United States. For more information about Alera Group, visit www.jmjwebconsulting.com

###

About Alera Group

With over 80 locations across the country and nearly 2,000 teammates, Alera Group works together to deliver solutions in employee benefits, property and casualty, retirement services and wealth management. Built on a unique model of collaboration, Alera Group is now the 17th largest independent insurance agency in the United States. For more information, visit jmjwebconsulting.com.

Steps to Take Before Launching Your Annual Benefits Enrollment

Posted on October 6th, 2020

Looking to take your virtual open enrollment to the next level? This on-demand webinar will help you create an engaging OE plan, even in the middle of a global pandemic.

Paper shuffling, bewildered looks, and frantic note-taking. It’s another open enrollment season — the annual 30-day period during which workers choose their benefits for the coming year

For calendar-year benefit plans that begin Jan. 1, open enrollment often takes place in November. However, enrollment this year won’t be business as usual. The COVID-19 pandemic and the need for social distancing have made things more complicated.

To add to enrollment challenges, this year more than ever, it’s imperative employers communicate with employees about their choices for benefits. Whether the benefits are health, dental, life insurance or ancillary benefits, employees must understand what benefits are available so they can best take advantage of them. They also need to know which benefits are fully paid for by the employer, which ones are employee-paid through salary deferral, and which ones are shared costs. 

There is no requirement that open enrollment be held for a certain length of time, although most employers have an open enrollment period of at least two to four weeks. To determine the timeline that works best for you, work backwards from the date that the information must be completed for the carriers and then work forward to deliver the communications program. Remember to send reminders to employees about the deadline for making their selections.

Before you start your open enrollment, give serious thought to how you will conduct open enrollment, taking into account social distancing. Typically, employers and carrier representatives hold enrollment meetings to discuss changes and options. If you decide you cannot safely hold a group meeting — either all at once or in stages — consider hosting a virtual enrollment meeting via a group video call.

Many small businesses still enroll employees through the traditional paper process. If that is your situation, talk to your broker and insurance carrier about going digital this year. If your carrier doesn’t have a system in place, it may be too late to implement a digital system this year, but you can start planning ahead now.

Best Practices

As always, there are procedures you can put in place to ensure that you have a successful enrollment period. Here are a few ideas recommended by benefit experts:

• Do your homework: It’s easiest to just offer the benefits you’ve always offered. Instead, review the demographics of your workforce and target benefits to their needs. For instance, young families have different needs than older workers who are nearing retirement age.
• Use different communication delivery systems: Don’t just rely on an email or one meeting. Your employees get information in a variety of ways. Try to use more than one of the following:

1. Webinars or video calls
2. In-person company meetings
3. Direct mail to their home
4. Social media
5. Videos
6. Intranet posts
7. Online decision tools
8. E-mails and instant messaging
9. Live hotline for questions and concerns
10. Infographics
11. Posters
12. Desktop dashboards or pop-up “Did you know?” benefits messages
13. Q&As

• Explain why the benefit package was chosen: Employees need to know why a certain package was chosen, and they want to know if there were changes to their benefits, such as increased health plan premiums or deductibles. You also can highlight the value of your benefits programs, promote wellness and encourage retirement savings.
• Inform managers and supervisors prior to the campaign launch: The more your company’s supervisors know about the plan and deadlines, the more they can encourage their team members to enroll 

If you have any questions, reach out to your Alera Group advisor or email us at info@aleragroup.com to learn more about how we can help you create an engaging open enrollment communication strategy.

IRS Extends Deadline for Furnishing Form 1095-C to Employees, Extends Good-Faith Transition Relief for the Final Time

Posted on October 5th, 2020

The Internal Revenue Service (IRS) has released Notice 2020-76, which extends the deadline for furnishing 2020 Forms 1095-B and 1095-C to individuals from January 31, 2021 to March 2, 2021.  The Notice also provides penalty relief for good-faith reporting errors and suspends the requirement to issue Form 1095-B to individuals, under certain conditions. 

The due date for filing the forms with the IRS was not extended and remains March 1, 2021 (March 31, 2021 if filed electronically).

The regulations allow employers to request a 30-day extension to furnish statements to individuals by sending a letter to the IRS with certain information, including the reason for delay; however, because the Notice’s extension of time to furnish the forms is as generous as the 30-day extension contained in the instructions, the IRS will not formally respond to requests for an extension of time to furnish 2020 forms to individuals.  Employers may obtain an automatic 30-day extension for filing with the IRS by filing Form 8809 on or before the due date. An additional 30-day extension is available under certain hardship conditions. The Notice encourages employers who cannot meet the extended due dates to furnish and file as soon as possible and advises that the IRS will take such furnishing and filing into consideration when considering whether to abate penalties for reasonable cause. 

Relief from Furnishing Form 1095-B to Individuals

Due to the individual mandate penalty being reduced to zero starting in 2019, an individual does not need the information on Form 1095-B in order to complete his or her federal tax return. Therefore, the IRS is granting penalty relief for employers who fail to furnish a Form 1095-B to individuals, provided that the reporting entity:

1. Posts a notice prominently on its website stating that individuals may receive a copy of their 2020 1095-B upon request, accompanied by an email address and a physical address where the request can be sent.  The notice must also include a phone number individuals can use to contact the reporting entity with questions; and
2. Furnishes an individual with a Form 1095-B within 30 days of a request.

Note that Applicable Large Employers (ALEs) are still required to furnish Form 1095-C to their full-time employees.  They must also complete Part III if the employee is enrolled in self-insured coverage. The relief from furnishing Form 1095-B does not extend to IRS reporting.  Forms 1095-B must still be submitted to the IRS, as applicable. 

In general, this relief from furnishing Form 1095-B applies to insurers, and non-ALEs that sponsor self-insured plans, as they complete Form 1095-B for covered participants.

Extension of Good-Faith Relief (Final Year)

As with calendar year 2015 – 2019 reporting, the IRS will not impose penalties on employers that can show that they made good-faith efforts to comply with the requirements for calendar year 2020. In determining good faith, the IRS will consider whether employers have made reasonable attempts to comply with the requirements (e.g., gathering and transmitting the necessary data to an agent or testing its ability to transmit information) and the steps that have been taken to prepare for next year’s reporting.  The Notice indicates that the good-faith relief was intended to be transitional relief, and therefore 2020 is the last year the IRS intends to provide this relief.

Note that the good-faith relief applies only to furnishing and filing incorrect or incomplete information, and not to a failure to timely furnish or file. However, if an employer is late filing a return, it may be possible to get penalty abatement for failures that are due to reasonable cause and not willful neglect. In general, to establish reasonable cause the employer must demonstrate that it acted in a responsible manner and that the failure was due to significant mitigating factors or events beyond its control.  The IRS has been enforcing late filing penalties via Letter 972CG, which may include penalties based on failed to file electronically (when required), or failure to file with correct TIN information.

As in past years, individuals can file their personal income tax return without having to attach the relevant Form 1095. Taxpayers should keep these forms in their personal records, even though the federal individual mandate penalty is not applicable for the 2020 filing year.

About the Authors.  This alert was prepared by Marathas Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act.  Contact Danielle Capilla at danielle.capilla@aleragroup.com with questions.

The information provided in this alert is not, is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers or our clients.  This is not legal advice.  No client-lawyer relationship between you and our lawyers is or may be created by your use of this information.  Rather, the content is intended as a general overview of the subject matter covered.  This agency and Marathas Barrow Weatherhead Lent LLP are not obligated to provide updates on the information presented herein.  Those reading this alert are encouraged to seek direct counsel on legal questions.

© 2020 Marathas Barrow Weatherhead Lent LLP.  All Rights Reserved.

Wellbeing Wrap-up: Alera’s Virtual Wellbeing Fair, Breaking Burnout and Everyday Kindness

Posted on October 5th, 2020

October 10th is World Mental Health Day so the Employer Resources section is chock full of webinars and resources that are available to you this week to dive deeper into supporting the Emotional Wellbeing of your teams. 

On a lighter note, if you had to cancel your Wellness Fair this year, Alera has created a Virtual Wellbeing Fair that is ready for you and your employees to enjoy!  During the week of October 19-23, your employees can participate in fitness breaks, mindfulness sessions, and a wide variety of Wellbeing breakout sessions.  Breakout sessions should be finalized tomorrow.  We are excited to have a 2-time Olympic Medalist as part of the line-up, as well as an array of national vendors speaking on a range of topics from mental health and support, how to communicate better in the workplace, and taking care of your personal and physical health. 

Have a safe and healthy week!

Career Wellbeing

• 4 Tips to Giving Great Feedback – For us to be successful leaders, teammates, parents, friends, spouses, and human beings, it’s important to give feedback effectively to those around us.  Mike Robbins shares 4 key things to remember when giving feedback to others.

Social & Family Wellbeing

• 31 Ways to Celebrate Halloween This Year –  While traditional door-to-door trick-or-treating may be discouraged or canceled this year, there are still plenty of ways to celebrate! 

Financial Wellbeing

• How to Create and Stick with a Holiday Budget –  With holiday spending, we often spend more than we plan.  Cash ends up feeling tight which takes away from the joy of the holidays.  Learn 10 steps to create a holiday budget now and decrease your financial stress.

Physical Wellbeing

• How Muscles Drive Metabolism with Dr. Gabrielle Lyon – In this podcast, Dr. Gabrielle fights protein food shaming with research-backed science on how protein intake supports fat loss and prevents sarcopenia, and she explains how muscles and proteins play a role in decreasing inflammation and how protein deficiency can manifest in disease.

Emotional Wellbeing

• Breaking the Burnout Cycle – Exhausted. Stressed. Anxious. Berating yourself for “not doing enough.” These are all signs of burnout. For years, we’ve known burnout affects women more than men, and now COVID-19 has made it even worse. This episode features Arianna Huffington, founder of The Huffington Post and Thrive Global, and Emily Nagoski, author of Burnout: The Secret to Unlocking the Stress Cycle. Arianna and Emily tell personal stories about burnout, teach us how to recognize it, and share tips for preventing and addressing it in our own lives.
• Change and Loss in the Workplace – Join Lori Schwanbeck and Wisdom Labs for a practice in processing grief and moving forward effectively. Change and loss are inevitable and can throw our personal, and professional, world into upheaval. Mindfulness practice creates a rudder that can guide us through these conditions with acceptance, courage and compassion. Bringing these qualities into our workplaces, we humanize the world of work, meeting ourselves and our colleagues with skill and care during times of vulnerability and suffering. October 8th at 12:PM ET. 

Community Wellbeing

• Everyday Kindness: How Small Acts Have Big Impact – Kindness positively contributes to all kinds of wellbeing.  While the dark days of the pandemic can lead us to focus on the negative, small acts of kindness can create a ripple effect of positivity. 

Employer Focused Wellbeing

• The Alera Virtual Wellbeing Fair – As referenced above, we would like to personally invite you and your employees to Alera Group’s first Virtual Wellbeing Fair. The event will be held the week of October 19th – 23rd. The event will include daily fitness breaks, daily mindfulness breaks and a wide array of national vendors speaking on a range of topics from mental health and support, how to communicate better in the workplace, and taking care of your personal and physical health. 
• The toll on our mental health: How can people leaders support caregivers during the pandemic – Multiple studies have surfaced illustrating the toll the pandemic is taking on the mental health of parents and caregivers.  Join this webinar to learn from brands that are innovating the policies and benefits they offer parents and caregivers, how they are getting creative, concrete ideas for adaptations, and how you can use data to make and validate the actions that you are taking.  Thursday, October 8th at 2PM ET. 
• Why Mental Resilience Matters and How to Build It – This webinar features a conversation with Arianna Huffington, Thrive Global Founder & CEO, Ellyn Shook, Accenture CHRO, and Joey Hubbard, Thrive Global Chief Training Officer. They will share how Accenture and Thrive have partnered to support workplace mental wellness and explore why building individual and organizational resilience is more important than ever.  Tuesday, October 6th at 10:30 AM ET.
• Stressed Beyond Belief: 3 Ways to Help Your Employees Now – Your employees are struggling. But do you know just how much?  Join clinical social worker and #1 bestselling author Julie Wald as she explains the state of employee mental health today. In this fast-paced, lunchtime webinar, she'll help you understand what employees are going through, how it affects your company, and what you can do about it.  Wednesday, October 7th at 12:30 PM ET
• The Headspace Mental Health Toolkit – In honor of World Mental Health Day on October 10th, Headspace is sharing their Workplace Mental Health Toolkit.  Get the latest research and best practices on mental health. 

About the Author

Andrea Davis, Director of Wellbeing
Andrea joined Alera Group Northeast (formerly CBP) in July 2013, bringing over 15 years of experience in management consulting and strategic solutions. As the Director of Wellbeing, she is responsible for assisting with the development, implementation and evaluation of comprehensive wellness strategies for existing and prospective Alera Group clients. She provides assistance and support to Alera Group clients by developing personalized programs that fit clients’ unique health management needs, wellness program implementation, committee development, promotion and marketing of their programs to encourage participation. In addition, Andrea conducts program analysis and generates reports related to program participation, health assessment and client utilization.