Category: Legal Alerts

On February 21, 2023, the IRS released Final Rules amending the existing requirements related to mandatory e-filing of information returns, including Forms 1094-C and 1095-C, among others.  The final rules are effective for all applicable returns due on or after January 1, 2024.  While the final rule requires electronic filing for a number of different information returns, such as Forms W-2 and 1099, which were previously allowed to be paper filed by employers of a certain size, this alert addresses the changes applicable to Forms 1094 and 1095, which must be filed by applicable large employers (ALEs) as well as non-ALEs who sponsor self-funded health plans.

Under the final rules, employers filing 10 or more returns must file Forms 1094 and 1095 (and their other applicable returns) electronically.  The 10-form threshold is determined based on the total number of forms the employer must file with the IRS, including Forms 1094 and 1095, as well as other information returns, such as Forms W–2 and Forms 1099, income tax returns, excise tax returns, and employment tax returns, including those that are not required to be e-filed, such as forms 940 and 941.  Previously, employers who filed less than 250 of the same ACA reporting forms were allowed to choose whether to file their applicable Forms 1094 and 1095 (either the B or C forms, as applicable) by paper or electronically.

The final rules allow employers to seek a waiver in cases of undue hardship.  Per the final rules, a key factor in determining whether hardship exists is whether the cost for filing the returns electronically exceeds the cost of filing the return on paper.  Entities seeking a waiver must specify the type of filing to which the waiver applies, the period to which it applies, and the entity must follow any applicable procedures, publications, forms, instructions, or other guidance, including postings to the IRS.gov website, when requesting the waiver. Further, the final rules allow the IRS to grant exemptions from the requirements in certain instances.

Conclusion

All ALEs and many non-ALEs (who report due to sponsoring a self-funded health plan) will be impacted by these changes and will be required to file their tax year 2023 Forms 1094 and 1095 electronically unless they seek and are granted a hardship exception by the IRS.  Impacted entities should take the time between now and next year to engage a filing vendor that can assist them with their electronic filing obligations.

On January 30, 2023, President Biden issued a Statement of Administration Policy announcing his intent to extend the COVID-19 national and public health emergencies (collectively, “COVID-19 Emergencies”) set to expire on March 1 and April 11, respectively, until May 11, 2023.  While the COVID-19 Emergencies have not officially been extended at this time, if they are extended through May 11, 2023, then they will end on that date. 

This announcement comes more than 3 months prior to the anticipated end of the COVID-19 Emergencies and is intended to ensure that states, group health plans, health insurers, health care providers, and health plan participants, among many others, have sufficient advance notice, as the end of the COVID-19 Emergencies may trigger significant changes for health plans and employee benefits which are described in more detail below.

Employee Benefits Provisions Tied to COVID-19 Public Health Emergency

COVID-19 Testing

The Families First Coronavirus Response Act, which was enacted on March 18, 2020, requires group health plans (self-funded, fully insured, grandfathered, and non-grandfathered plans, but not excepted benefits such as dental or vision) and health insurance issuers to cover testing or certain other items or services intended to diagnose COVID-19 without cost-sharing (deductibles, copays, or coinsurance), prior authorization, or other medical management requirements.  It also permits federal agencies to implement the FFCRA through sub-regulatory guidance, program instruction, or otherwise.  The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which was enacted on March 27, 2020, expanded the FFCRA to, among other things, include a broader range of reimbursable COVID-19 diagnostic items and services that must be covered without cost-sharing, prior authorization, or medical management during the public health emergency, including testing provided by out-of-network (OON) providers.

As the COVID-19 pandemic progressed and the FDA authorized at-home OTC COVID-19 diagnostic tests that individuals could self-administer and self-read to diagnose COVID-19, on January 10, 2022, the agencies released initial guidance for plans and carriers, which required them to cover FDA approved at-home, OTC COVID-19 tests (up to 8 total per individual per month) without cost sharing, prior authorization, or medical management, and without the need for a prescription or recommendation of a health care provider during the pendency of the COVID-19 public health emergency.  Additional FAQs clarifying some of the initial guidance were released on February 4, 2022. 

COVID-19 Vaccines

Additionally, the CARES Act requires the COVID-19 vaccine to be provided cost-free (similar to other preventive care vaccines) by any non-grandfathered group health plan pursuant to the ACA’s preventive care rules, regardless of whether the vaccine is administered by an OON or in-network (INN) provider. 

Employee Benefits Provisions Tied to COVID-19 National Emergency

Group Health Plan Notification, Premium, and Claims Filing Deadlines Applicable to Participants

On April 28, 2020, in an effort to assist employees in meeting their various notice, election, and claims filing deadlines that were severely disrupted as the nation was in shutdown, federal agencies (the DOL, HHS, and IRS) released the Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak Final Rule (“Covid-19 Extension Final Rule”) which provided participants, enrollees, and members with relief from the below applicable deadlines from March 1, 2020 until 60 days after the end of the COVID-19 national emergency:

• The 30-day period (or 60-day period, if applicable) to request a special enrollment;
• The 60-day election period for COBRA continuation coverage;
• The deadline for making COBRA premium payments;
• The deadline for individuals to notify the plan of a qualifying event or determination of disability;
• The deadline within which employees can file a benefits claim, or a claimant can appeal an adverse benefit determination, under a group health plan’s or disability plan’s claims procedures;
• The deadline for claimants to file a request for an external review after receipt of an adverse benefit determination or final internal adverse benefit determination; and
• The deadline for a claimant to file information to perfect a request for external review upon finding that the request was not complete.

The above relief was further extended in EBSA Disaster Relief Notice 2021-01, which extended the above deadlines until the earlier of: (a) one (1) year from the date (on or after March 1, 2020) that an individual is first eligible for relief; or (b) 60 days after the end of the COVID-19 national emergency. 

Group Health Plan Notice and Disclosure Requirements Applicable to Plan Sponsors

Relief was not only provided to employees. The COVID-19 Extension Final Rule and EBSA Disaster Relief Notice 2021-01, provided group health plans with relief from providing COBRA election notices for qualifying events occurring from the earlier of (a) one (1) year from the date (on or after March 1, 2020) that the group health plan was eligible for relief; or (b) 60 days after the end of the COVID-19 national emergency. 

Group health plans and plan sponsors were also afforded relief due to COVID-19 disruptions in EBSA Disaster Relief Notice 2020-01, which eased the burden for group health plans, disability plans, and pension plans to provide notices and disclosures required under ERISA and Internal Revenue Code of 1986 (the “Code”) by providing good faith relief for plans or employers who fail to timely furnish a notice, disclosure, or document if they make any required notice or disclosure as soon as administratively practicable under the circumstances from the period of March 1, 2020, through 60 days after the announced end of the COVID-19 National Emergency. 

Additionally, pursuant to EBSA Disaster Relief Notice 2020-01, group health plans were provided relief from certain ERISA electronic disclosure requirements for plan participants and beneficiaries who they reasonably believed had effective access to electronic means of communication, including email, text messages, and continuous access websites.

Impact of the End of the COVID-19 Public Health and National Emergencies

If the COVID-19 Emergencies end as of the date indicated in the Statement of Administration Policy, then all of the above-referenced relief will expire as follows:

• The provisions of the FFCRA and CARES Act which require COVID-19 diagnostic tests to be provided without cost-sharing (deductibles, copays, or coinsurance), prior authorization, or other medical management requirements are tied to the COVID-19 public health emergency and, therefore, will expire on May 11, 2023, when the public health emergency ends. Accordingly, group health plans and insurers will no longer be required to cover COVID-19 at-home or in-person diagnostic tests without cost sharing. Any plan materials, such as SPDs, describing coverage for COVID-19 testing by the plan should be amended as necessary.
• Provisions governing coverage of the COVID-19 vaccine are also tied to the COVID-19 public health emergency.  Therefore, after May 11, 2023, administration of the COVID-19 vaccine will still be covered without cost (similar to other preventive care vaccines) by health plans and insurers; however, plans and insurers will not be required to cover vaccines administered by OON providers. Any plan materials, such as SPDs, describing coverage for COVID-19 vaccines by the plan should be amended as necessary.
• The COVID-19 Extension Final Rule and EBSA Disaster Relief Notice 2021-01 are tied to the COVID-19 national emergency declaration and will expire on July 10, 2023 (which is 60 days after the end of the COVID-19 national emergency).  Thus, all extensions under the COVID-19 Extension Final Rule that are still effective for any plans or participants (i.e., those that are still in the 1-year extension window) will expire and the applicable clock will begin ticking.  For example, if an individual received their COBRA election notice on October 1, 2022, the time from October 1, 2022, through July 10, 2023, is disregarded due to the COVID-19 Extension Final Rule.  After the outbreak period ends on July 10, 2023, the individual would have until 60 days after July 10, 2023, to elect COBRA, or September 8, 2023. Therefore, it is imperative that employers use the time between now and May 11 to inform participants and beneficiaries of these upcoming changes so they understand how their rights will be impacted. Any plan materials, such as SPDs, notices, or other communications describing these extensions should be amended accordingly.
• Finally, EBSA Disaster Relief Notice 2020-01 is also tied to the COVID-19 national emergency.  Accordingly, after July 10, 2023, employers will no longer have relief from timely providing required notices to participants,  and any employers who used the relief as a basis to justify electronic delivery of ERISA plan materials will need to ensure they comply with ERISA electronic delivery requirements for plan materials.

Conclusion

While employers do not need to do anything at this time, particularly as the COVID-19 Emergencies’ end date has not been officially announced, the Statement of Administration Policy indicates that the COVID-19 Emergencies will likely be coming to an end in the next several months.  Therefore, employers who sponsor group health plans are encouraged to work with their carriers, TPAs, COBRA administrators, and other vendors to develop strategies for ensuring proper communication of the end of the COVID-19 Emergencies and the impact on participants and their benefits.  Further, they should identify SPDs and other plan materials that may need to be amended. Additionally, any employers subject to ERISA who relied upon the relaxed electronic delivery standards set forth in Notice 2020-01 and 2021-01 should ensure they review their workforce and strategies to ensure compliance with electronic delivery requirements after July 10, 2023 (unless a different COVID-19 national emergency end date is otherwise announced).

________________________________________

About the Authors.  This alert was prepared by Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act.  Contact Stacy Barrow or Nicole Quinn-Gato at sbarrow@marbarlaw.com or nquinngato@marbarlaw.com.

This email is a service to our clients and friends.  It is designed only to give general information on the developments actually covered.  It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.

Benefit Advisors Network and its members are not attorneys and are not responsible for any legal advice.  To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.

© Copyright 2023 Benefit Advisors Network. All rights reserved.

CAA, 2023 Eliminates MHPAEA Exemption for Self-Funded Non-Federal Governmental Health Plans

On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023  (“CAA, 2023”), into law.  The CAA 2023, which is largely a bipartisan spending bill, sunsets provisions of the Public Health Service Act which permitted large, self-funded, non-federal governmental plans (i.e., self-funded state and local governmental plans) to opt out of the Mental Health Parity and Addiction Equity Act (“MHPAEA”). Essentially, this means any self-funded state and local governmental plans that have not previously elected to opt out of the MHPAEA will no longer be able to submit an election to opt out.  Further, any self-funded state and local governmental plans that previously elected to opt out of the MHPAEA will be unable to renew their election once it expires.

There is an exception for certain collectively bargained, non-federal governmental plans with existing opt outs that are subject to multiple collective bargaining agreements (“CBA”) with varying lengths. These plans may extend their opt out elections until the date on which the term of the last CBA expires.

Background

The MHPAEA prohibits a group health plan from applying financial requirements (e.g., deductibles, co-payments, coinsurance, and out-of-pocket maximums), quantitative treatment limitations (e.g., number of treatments, visits, or days of coverage), or non-quantitative treatment limitations (such as restrictions based on facility type) to its mental health and substance use disorder benefits that are more restrictive than those applied to the plan’s medical and surgical benefits. 

With limited exceptions, the MHPAEA applies to both self-funded, fully insured, grandfathered and non-grandfathered group health plans offering medical/surgical benefits and mental health and substance use disorder benefits. Certain plans may be exempt from the MHPAEA requirements, including: (1) self-insured plans sponsored by employers with 50 or fewer employees, (2) group health plans and group or individual health insurance coverage consisting only of excepted benefits, (3) retiree-only group health plans, and (4) group health plans and health insurance issuers who are exempt due to an increased cost.  Note, small employer plans that are fully insured are indirectly required to comply with the MHPAEA by meeting the essential health benefit requirements of the Affordable Care Act.

Large, self-funded non-federal governmental employers were previously also able to opt out of MHPAEA compliance by filing a HIPAA Exemption Election with CMS prior to the beginning of each plan year, issuing a notice of opt-out to their enrollees at the time they first enrolled and annually thereafter, and filing an opt-out notice or certification of that the opt out notice has been provided to participants with CMS.

CAA, 2023 Sunset

The CAA, 2023, sunsets the HIPAA Exemption Election opt out from MHPAEA requirements for large, self-funded non-governmental employers by eliminating the ability for plans that have not previously sought an exemption from applying for a new exemption after December 29, 2022, and by eliminating the ability of large, self-funded non-federal governmental employers who have a current exemption from renewing that exemption once such exemption election expires (i.e., for exemption elections that expire 180 days from the date the CAA, 2023 is enacted). 

A limited exception applies for non-federal governmental plans subject to multiple CBAs with varying lengths. These plans may seek to have their exemption elections renewed until the date on which the term of the last CBA expires. Essentially, this means non-federal governmental employers will be able to honor their CBA commitments for the remainder their current CBA terms.

Conclusion

Any large, self-funded state or local governmental plan sponsors who have a current exemption election from the MHPAEA requirements should coordinate with their broker and third-party administrators to understand how these changes may be implemented and any potential resulting impact to their plan terms and costs.

___________________________

About the Authors.  This alert was prepared by Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act.  Contact Stacy Barrow or Nicole Quinn-Gato at sbarrow@marbarlaw.com or nquinngato@marbarlaw.com.

This email is a service to our clients and friends.  It is designed only to give general information on the developments actually covered.  It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.

Benefit Advisors Network and its members are not attorneys and are not responsible for any legal advice.  To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.

© Copyright 2023 Benefit Advisors Network. All rights reserved.

On December 23, 2022, federal agencies released ACA and CAA Implementation FAQ Part 56 which extends the December 27, 2022 deadline for Prescription Drug Data Collection Reporting (“RxDC Reporting”) through January 31, 2023, and provides relief for plans that use a good faith, reasonable interpretation of the regulations and RxDC Reporting Instructions when submitting their data for the 2020 and 2021 reference years.  Further, as discussed below, the FAQ offers guidance and provides additional flexibility to assist group health plans and health insurance issuers in accomplishing the reporting.

Background

The Consolidated Appropriations Act, 2021 (“CAA, 2021”) included a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to prescription drug and other health care spending, including, but not limited to: (1) general information regarding the plan or coverage; (2) the 50 most frequently dispensed brand prescription drugs; (3) the 50 most costly prescription drugs by total annual spending; (4) the 50 prescription drugs with the greatest increase in plan expenditures over the preceding plan year; (5) total spending by the plan or coverage broken down by the type of costs; (6) the average monthly premiums paid by participants, beneficiaries, and enrollees and paid by employers; and (7) the impact of premiums on rebates, fees, and other remuneration paid by drug manufacturers to the plan or coverage or its administrators or service providers, including the amount paid with respect to each therapeutic class of drugs and for each of the 25 drugs that yielded the highest amount of rebates and other remuneration under the plan or coverage from drug manufacturers during the plan year.

Pursuant to the CAA, 2021, initial reporting for the 2020 reference year was to be reported on December 27, 2021, and then each June 1^st thereafter for future reference years, making the 2021 reference year reporting due June 1, 2022.  However, when the agencies released final rules on November 23, 2021, which extended the statutory deadlines for plans and issuers to submit their 2020 and 2021 reference year reporting to December 27, 2022.  Thereafter future reference year reporting will be due each June 1^st. 

FAQ #56

Recognizing the operational challenges for coordinating data among multiple reporting entities and submitting data that is accurately classified, compiled, and validated, the agencies provided the following guidance, flexibility, and/or relief related to RxDC Reporting for the 2020 and 2021 reference years:

• Plans and issuers have a grace period for submitting the required RxDC Reporting from December 27, 2022 through January 31, 2023, and plans and issuers will not be considered to be out of compliance if they make a good faith submission of the 2020 and 2021 reference year data on or before January 31, 2023.
• The departments will not take enforcement action against plans or issuers who use a good faith, reasonable interpretation of the regulations and the RxDC Reporting Instructions when submitting their reporting.
• Reporting entities who submit RxDC Reporting data on behalf of more than one plan or issuer for a reference year may create more than one submission in HIOS for that reference year (in lieu of one submission combining the data of all clients within a single set of plan lists and data files).
• For plans or issuers who have data required from more than one reporting entity for the same plan, the data from the multiple reporting entities is not required to be compiled into a single data file for each type of data. Instead, each reporting entity may submit the same data file type on behalf of the same plan or issuer.
• Data aggregation requirements for multiple reporting entities that submit required data on behalf of one or more plans or issuers in a state and market segment are relaxed in that a reporting entity can submit such required data aggregated at a level less granular than the level of aggregation that is used by the reporting entity that submits the total annual spending on health care services data.
• Plans and issuers who are only submitting the plan list, premium and life-years data, and narrative response (i.e., no other data than that listed here), are not required to submit this information in the HIOS RxDC Module. Instead, they can email the information to:  RxDCsubmissions@cms.hhs.gov.  The email must include the plan list file, premium and life years data (data file D1), and a narrative response, and the naming convention for these files must include the reference year, the plan list or data file type (e.g., P2, D1), and the name of the plan sponsor.  Plans and issuers may also include any optional supplemental documents. 
• Reporting National Drug Codes for vaccines, which were only recently included in the CMS drug name and therapeutic class crosswalk (“crosswalk”) when the crosswalk was updated on October 3, 2022, is optional for plans and issuers.
• Reporting entities are not required to report a value for “Amounts not applied to the deductible or out-of-pocket maximum” and the “Rx Amounts not applied to the deductible or out-of-pocket maximum”. The columns associated with this data should not be removed from the files; instead, the data fields in the columns can be left blank.

Conclusion As set forth above, plans and issuers have until January 31, 2023 to submit the required RxDC Reporting and must use a good faith, reasonable interpretation of the regulation and RxDC Reporting Instructions when preparing their submissions. They should ensure any of their reporting entities are aware of the FAQs and are prepared to timely comply with all applicable regulations and guidance when completing their submissions. Plans and issuers who take advantage of alternative reporting (via email in lieu of the HIOS RxDC Module) must ensure they are only submitting data that is subject to the relief (P2, D1, and a narrative response) or optional supplemental documents, and that their data files comply with the required naming conventions. At this point, this relief is for the 2020 and 2021 reference years only. RxDC Reporting for the 2022 reference year is due on June 1, 2023, and all or part of this relief may not be available at that time.

_________________________________

About the Authors.  This alert was prepared for [insert agency name] by Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act.  Contact Stacy Barrow or Nicole Quinn-Gato at sbarrow@marbarlaw.com or nquinngato@marbarlaw.com.

_{This email is a service to our clients and friends.  It is designed only to give general information on the developments actually covered.  It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion. Benefit Advisors Network and its members are not attorneys and are not responsible for any legal advice.  To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.}

© Copyright 2022 Benefit Advisors Network. All rights reserved.

IRS Releases Final Rules Extending Deadline to Furnish ACA Reporting Forms

On December 12, 2022, the IRS released a Final Rule providing for, among other things,  an automatic 30-day extension of time for applicable large employers (“ALEs”) to furnish annual Forms 1095-C to individuals for calendar years beginning after December 31, 2022. The Final Rule is substantially consistent with the proposed rule issued by the IRS in November 2021 which employers were permitted to rely upon for their calendar year 2021 Forms 1095-C (which were due in 2022).

Prior to the IRS releasing its proposed rule last year, the IRS could grant an extension of time of up to 30 days to furnish Forms 1095-B and 1095-C to individuals for good cause shown; however, recognizing the January 31 deadline was difficult to meet, the proposed rule eliminated the good cause shown standard and simply allowed for an automatic 30-day extension to furnish the forms to employees.  The Final Rule does the same and, consistent with the proposed rule, provide that in years where the deadline falls on a weekend or holiday, the forms are due the next business day. 

The deadline to file the Forms 1094-B or C and 1095-B or C with the IRS are not extended and will remain February 28 for paper filings and March 31 if filed electronically, though pursuant to current regulations, companies may receive an automatic 30-day extension of time to file the forms with the IRS by submitting Form 8809, Application for Extension of Time to File Information Returns, on or before the due date for filing the forms.

Additionally, because the penalty for the individual mandate is currently $0, for any calendar year in which it remains $0, the Final Rule provides relief (consistent with relief provided for tax years 2019, 2020, and 2021) from furnishing Forms 1095-B to individuals, if the responsible reporting entity:

1. Posts a clear and conspicuous notice in a location on its website that is reasonably accessible to individuals stating that individuals may receive a copy of their 1095-B upon request, accompanied by an email address, phone number and a physical address where the request can be sent;
2. Furnish an individual with a Form 1095-B within 30 days of a request; and
3. Retain the notice in the same location of its website until October 15 – or the first business day following October 15 if October 15 falls on a weekend or holiday – of the next calendar year. This would be October 15, 2024 for the tax year 2022 Form 1095-B.

The website notice must be written in plain, non-technical terms and with letters of a font size large enough, including any visual clues or graphical figures, to call a viewer’s attention that the information pertains to tax statements reporting that individuals had health coverage.  Per the IRS a statement or link on the company’s main page reading “Tax Information”, which takes users to a secondary page that includes a statement in capital letters such as “IMPORTANT HEALTH COVERAGE TAX DOCUMENTS”, would meet this requirement.  This relief from providing the B-series forms typically applies to insurance companies (who are required to file and furnish Forms 1095-B to participants in their fully insured plans), non-ALEs with self-insured plans, and ALEs who provide coverage under a self-insured plan to individuals who were not full-time employees during any part of the year (e.g., part-time employees, or retirees or COBRA participants in the year following retirement or termination of employment). The notice on the website must explain how responsible individuals (for purposes of the 1095-B provided by non-ALEs who sponsor self-insured plans or insurance carriers) or non-full-time employees or non-employees enrolled in an ALEs plan (for purposes of the 1095-C) may request a copy of their form.

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. Further, 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. 

The Final Rule, which is effective on December 15, 2022, applies for calendar years beginning on or after December 31, 2021 (though pursuant to the proposed rule and Final Rule, employers were permitted to apply the relief for calendar year 2021 forms).  Accordingly, the relief applies for upcoming calendar year 2022 forms which means employers have an automatic extension to March 2, 2023 to furnish the forms.

Conclusion Based on the Final Rule, ALEs have until March 2, 2023 to furnish Forms 1095-C to individuals, but still must meet the February 28 (paper filing) or March 31, 2023 (electronic filing) deadlines to file Forms 1095-C with the IRS.  Moreover, as long as the individual mandate penalty remains $0, insurance carriers, non-ALEs with self-funded plans, and ALEs with self-funded plans who provide coverage to part-time employees or non-employees, are not required to furnish Forms 1095-B to individuals if they meet the requirements for posting information regarding how individuals may receive copies of their Form 1095-B.

_____________________

About the Authors.  This alert was prepared for [insert agency name] by Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act.  Contact Stacy Barrow or Nicole Quinn-Gato at sbarrow@marbarlaw.com or nquinngato@marbarlaw.com.

This email is a service to our clients and friends.  It is designed only to give general information on the developments actually covered.  It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion. Benefit Advisors Network and its members are not attorneys and are not responsible for any legal advice.  To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.  

© Copyright 2022 Benefit Advisors Network. All rights reserved.