Compliance Alerts

We Are Here For You.

The coronavirus is top of mind for companies and their employees. Below you can find information and guidance released from our Compliance Center of Excellence about current legislation and issues that impact employers.

In addition, you can click here to visit our dedicated page with resources and information we trust about the current outbreak of coronavirus disease (COVID-19) that was first reported from Wuhan, China, on 31 December 2019.

All our clients receive regular e-newsletter alerts. From the recently passed Families First Coronavirus Response Act to ERISA to the Affordable Care Act, annual reminders, and new Paid Family Leave legislation, our experts and attorneys help keep you up to date and compliance.

A Coronavirus Update for Employers –
Trying to Remain Calm in Troubled Times

Remaining calm is easier said than done given the relentless stream of news about the spread of novel coronavirus (“COVID-19”) across the globe. This article summarizes recent articles taken by both the federal and state governments affecting employer-provided health benefits as well as certain other related issues.

This article covers the following:
Families First Coronavirus Response Act
States are Addressing Coverage for COVID-19
High Deductible Health Plans
Spending Account Plans
Other Coverage Options for Employees
Potential Increase in Appeals?
Data Privacy Concerns
Certain Labor & Employment Issues
The Affordable Care Act and the Employer Mandate
The WARN Act
Additional Resources

Please contact your MMA Trion representative directly with any questions or concerns.

Click here to read the full alert – Updated March 30, 2020

IRS Notice 2020-15

This is a follow up to the MMA Trion Special Alert on Coronavirus Testing Benefit Considerations released on Tuesday, March 10, 2020. The Department of Treasury and the Internal Revenue Service (IRS) issued guidance through IRS Notice 2020-15 that allows the coverage of COVID-19 on a first dollar basis without rendering a qualified high deductible health plan (HDHP) ineligible for use with a Health Savings Account (HSA). The full notice is available at:  https://www.irs.gov/pub/irs-drop/n-20-15.pdf


Click here to read the full alert


If you have any questions or need further details, please contact your client service team.

Federal Agencies Issue Proposed Rules Addressing Transparency in Coverage

The proposed rules on Transparency in Coverage were published by the Department of Health and Human Services, the Department of Labor and the Department of Treasury (the “Agencies”) on November 27, 2019. These rules were generated in response to President Trump’s June 2019 Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First. If enacted as written, the rules will provide health plan participants with greater access to health care cost information than is generally available or required today.

Click here to read the full alert


If you have any questions or need further details, please contact your client service team.

Annual CMS Medicare Part D Disclosure Due for Calendar-Year Plans – February 14, 2020

Reporting Creditable or Non-Creditable Status to CMS

As part of the annual notification requirements under the Medicare Modernization Act (MMA), employer-sponsored group health plans that provide prescription drug coverage are required to disclose the plan’s creditable or non-creditable coverage status to the Centers for Medicare & Medicaid Services (CMS). This online disclosure is due sixty (60) days after the first day of each plan year, and for calendar year plans it should be made by February 29, 2020 (but see Timing of the Disclosure to CMS Form below).

This alert provides a summary of the Medicare Part D disclosure requirements including a review of:

If you have any questions or need further details about the creditable coverage disclosure requirements, please contact your client service team.

Click here to read the full alert

Guide to the State Individual Mandates – February 10, 2020

The Rise of State Individual Mandates

Restoring an Affordable Care Act (ACA) Requirement

As of 2019, the Tax Cut and Jobs Act of 2017 reduced the ACA’s individual mandate penalty to $0. In reaction, several states and the District of Columbia have enacted their own ACA-style individual mandates requiring taxpayers to provide proof of health coverage to avoid financial penalties. This article focuses on the obligations for employers sponsoring group medical coverage and summarizes what we know so far.

Note: We intend to update this article as new or additional state individual mandate guidance becomes available. This article is current as of the publication date appearing at the top of this page.

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ACA Mandate Part 4 – January 23, 2020

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2020 Spending Package and 5th Circuit ACA

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2019 ACA Reporting Relief

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IRS Releases Draft 2019 Instructions for Forms 1094/1095

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IRS Releases 2020 FSA Limits

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Compliance Center of Excellence Newsletter – Volume 7

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New Health Reimbursement Arrangements Allowed Under Final Rules-September 30, 2019

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Compliance Center of Excellence Newsletter – Volume 6

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Medicare Part D Notice – September 23, 2019

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AHP Update – August 13, 2019

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Expanding Preventive Care for HDHPs

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Exec Order on Price and Quality Transparency – June 28, 2019

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New HRAs Allowed Under Final Rules – June 18, 2019

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Compliance Center of Excellence Newsletter – Volume 4

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Compliance Center of Excellence Newsletter – Volume 3

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DOL Releases Proposed Overtime Rule

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Compliance Center of Excellence Newsletter – Volume 2

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Compliance Center of Excellence Newsletter – February 2019

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February Reminder – Annual CMS Disclosure

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Texas Federal Court Rules ACA Unconstitutional…But Please Sit Tight

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Compliance Center of Excellence Newsletter – December 2018

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Massachusetts Employers Must File HIRD Form by November 30

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Compliance Center of Excellence Newsletter – November 2018

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Compliance Center of Excellence Newsletter  – October 2018

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Reminder: Medicare Part D Creditable Coverage Notice Deadline is October 14, 2018

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Federal Agencies Release Final Regulations for Short-Term Limited Duration Insurance Coverage

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Agencies Issue Guidance on Mental Health Parity Issues, Signal Enhanced Enforcement

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IRS Grants Relief for Reduction to 2018 HSA Tax Limits

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IRS Announces Reductions to 2018 HSA and Adoption Credit Tax Limits

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Reminder: Annual CMS Medicare Part D Disclosure

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DOL Announces April 1 Applicability of Final Disability Plan Claims Procedure Regulations

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COMPLIANCE ALERT

Time-sensitive alerts about legislative events and regulatory reminders such as spending account contribution limits and required annual notices.

HCR ALERT

Short alerts sent within 48-72 hours of any newsworthy healthcare legislation events. Stay ahead of the curve 24/7/365 with Trion.

HCR NEWS

Comprehensive newsletters explaining recent healthcare legislative events and providing our experts’ opinions on what actions are required of employers.

New HRAs Allowed Under Final Rules – June 18, 2019

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Compliance Center of Excellence Newsletter – Volume 4

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Compliance Center of Excellence Newsletter – Volume 3

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DOL Releases Proposed Overtime Rule

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Compliance Center of Excellence Newsletter – Volume 2

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February Reminder – Annual CMS Disclosure

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Texas Federal Court Rules ACA Unconstitutional…But Please Sit Tight

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Massachusetts Employers Must File HIRD Form by November 30

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Reminder: Medicare Part D Creditable Coverage Notice Deadline is October 14, 2018

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Federal Agencies Release Final Regulations for Short-Term Limited Duration Insurance Coverage

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Agencies Issue Guidance on Mental Health Parity Issues, Signal Enhanced Enforcement

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IRS Grants Relief for Reduction to 2018 HSA Tax Limits

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IRS Announces Reductions to 2018 HSA and Adoption Credit Tax Limits

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Reminder: Annual CMS Medicare Part D Disclosure

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DOL Announces April 1 Applicability of Final Disability Plan Claims Procedure Regulations

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HCRAlerts

DOL Releases Final Rule Expanding Association Health Plans

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IRS Announces ACA Health Plan Affordability Threshold For 2019

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ACA 2019 Notice of Benefit and Payment Parameters & Individual Mandate Exemptions

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Agencies Release Proposed Regulations on Short-Term Limited Duration Insurance

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ACA Cadillac Tax Delayed Another Two Years

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Court Vacates EEOC’s Wellness Program Incentives Rules Effective January 1, 2019

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Health Care Reform News

DOL Proposes Rule to Expand Association Health Plans

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Employee Benefit Changes in the Tax Cuts and Jobs Act Of 2017

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