4 Point Compass: Winter 2022

Chicago rookery building

Mandatory COVID Testing Coverage – On January 10, the federal government released guidance that all group healthcare plans must cover over-the-counter COVID-19 diagnostic tests, whether or not they had been ordered by a medical provider.  This coverage begins January 15 and goes through the end of the public emergency, and will cover up to 8 tests per month per covered member.  Group healthcare plans must either pay for the OTC test upfront (at time of purchase) or reimburse members’ expenses at a later date.  Insurance carriers are working on guidance on how members can submit OTC testing claims, so watch for more information on that from your carrier. 

1095 Information & DIY Online Solution – The Affordable Care Act requires Applicable Large Employers (i.e. employers with 50 or more full-time + “full-time equivalent” employees in 2020, including members of an aggregated group or under common control) and smaller employers providing self-insured medical coverage to employees in 2021, to provide a 2021 Form 1095-C to employees.  The Form 1095-C should be provided to all eligible full-time employees (full-time as defined by ACA) whether they were enrolled in health coverage or not and who were employed for any period of time in the reporting year (2021).  Additionally, retirees and/or COBRA enrollees that had coverage in the reporting year (2021) also need to receive a Form 1095-C.  The deadline for providing the Form 1095-C to all eligible full-time employees, retirees & COBRA enrollees is no later than March 2nd, 2022 (That date was extended from January 31st, 2022).  While this deadline was extended by the IRS, the deadline for filing the forms with the IRS has not been extended, so employers must submit their paper forms to the IRS by February 28, 2022 (or electronically by March 31st, 2022).  To transmit the 1095-C forms to the IRS, the Form 1094-C must be completed and used to report to the IRS summary information.  A quick reminder that Stumm Insurance (SI) offers a “Do-It-Yourself” (DIY) 1095-C online solution at no cost to you.  See the attached DIY1095 flyer for more information and contact your SI service team as soon as possible if you would like discuss/demo this solution. 

Reminder: Stumm Insurance is Able to Provide SPD’s – Since its passage in 1974, ERISA requires employers with a benefit plan to maintain and distribute a Summary Plan Description (SPD) & Plan Document.  While the likelihood of being found without one is minimal, failure to have these documents could result in a substantial penalty.  Many companies mistakenly assume that insurance contracts, certificates of insurance, and benefits summaries fulfill the ERISA requirements, but they do not include the required provisions that protect the employer completely.   Typically, the cost to develop an SPD can be expensive, often over $2,000.  But Stumm Insurance has solved this problem for you, and we wanted to remind you that we can provide one to you at no cost.  We continue to have a sophisticated ERISA-compliant system that can create a customized “wrap” SPD and Plan Document for your company, which wraps around your existing documents to comply with ERISA.  If you do not already have one, please let your Stumm Insurance representative know if you would like one to be created for you. 

HR360 Resource Available – Employee benefit & labor laws continue to provide human resources & compliance challenges to employers, so we wanted to remind you of a free service that Stumm Insurance (SI) provides to you.  All SI clients have access to HR360 – a website which provides a vast library of HR resources and guidance on issues such as compliance, benchmarking, legal questions, labor law and many other areas (see flyer attached).  All information is accessed with a “search engine” function – think of it as a “Google for HR” – and here is a two minute video on how it works: https://www.youtube.com/watch?v=C1GMtNcDU4c  If you have not previously taken advantage of this great resource (or do not have your log-in information), please contact your SI Rep to obtain a username and password.

Lastly, we want to make you aware of a new Illinois employer requirement that we are currently awaiting for more guidance on.  Recently, Illinois passed the “Consumer Coverage Disclosure Act” which requires any employer (including local governments, school districts and employers outside of Illinois) that both (1) has employees who are “gainfully employed in Illinois” and (2) offers group medical benefits to provide all eligible employees (not just those enrolled) a written list of the covered benefits provided by the group plan.  It must compare the group medical benefits with the benefits considered “essential health benefits” under Illinois law.  ?Employers must provide this information to all employees upon hire, annually, and upon request.  The Illinois Department of Labor recently published a FAQ and a Model form that employers can use to disclose the information.  Again, we are awaiting for guidance from the insurance carriers and will keep you updated. 

Should you have any further questions, please feel free to contact your Stumm Insurance Client Service Team.