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Northwest OH Legal Blog

Friday, May 1, 2015

Court Rules That Health Care Premium Increase Is Loss of Health Care Coverage for COBRA Purposes

In a case that expands the boundaries of a so-called “qualifying event” and notice requirements under the Consolidated Omnibus Budget Reconciliation Act (“COBRA”), a federal trial court has ruled that a premium increase may be considered a loss of coverage for purposes of determining whether an employee has experienced a COBRA qualifying event.

Background.  In Green v. Baltimore City Board of School Commissioners, 2015 WL 302812 (D. Md. 2015), two employees who were suspended from their jobs without pay and were subsequently terminated filed a lawsuit against their employer (in the employer’s role as plan administrator), the Baltimore City Board of School Commissioners.  For both employees, coverage under their employer’s health plan automatically continued during their suspensions—a fact of which they first became aware months later, upon receiving invoices for the full accumulated premium amount (both employer and employee contributions) for health care coverage.  The employees sued the employer for the employer’s failure to provide a timely COBRA election notice and for breach of fiduciary duty under the Employee Retirement Income Security Act of 1974 (“ERISA”).

The employer argued that the employees did not experience a COBRA qualifying event at the time of their suspension because they had a reduction in hours, but no loss of coverage.  Instead, coverage continued until the employees either requested cessation of coverage or terminated employment. The employees asserted that, to the contrary, when they became obligated to pay both the employee and employer shares of their health care premiums, the premium increase resulted in a loss of coverage.

Legal Guidance.  In general, COBRA qualifying events are events that cause an individual to lose his or her group health plan coverage. The type of qualifying event determines who the qualified beneficiaries are for that event and the period of time that a plan must offer continuation coverage.  The following are COBRA qualifying events for covered employees if they cause the covered employee to lose coverage:

  • termination of the employee's employment for any reason other than gross misconduct; or
  • reduction in the number of hours of employment.

Court Holding.  Following a bench trial, the court ruled for the employees.  The court acknowledged the correctness of the employer’s assertion that a reduction in hours, standing alone, is not sufficient to trigger a COBRA notice obligation.  However, in the court’s view, the employer had too narrowly construed the term “loss of coverage” as a loss of eligibility.  The court agreed with the employees that the premium increase constituted a loss of coverage, citing Internal Revenue Service regulations under which losing coverage means ceasing to be covered under the same terms and conditions as in effect immediately before the qualifying event.  In this case, because the loss of coverage was triggered by the reduction in hours, the employees experienced a COBRA qualifying event, and the employer did not meet its COBRA notice obligations.

The court further ruled that the employer’s failure to adequately inform the employees of the premium increase resulting from the suspension constituted a breach of its fiduciary duty under ERISA, noting that a fiduciary is obligated to communicate material facts that participants need to know for their own protection.  The court declined to assess penalties (because the employees’ complaint sought only the invalidation of the retroactive invoices) but stated that the employees were free to petition for further relief.

Key Takeaway.  In general, a COBRA qualifying event requires both a triggering event and a related loss of coverage under a group health plan.  The court’s holding in Green illustrates that a loss of coverage may include not only a complete loss of eligibility, but also an increase in the required premium, a reduction in benefits, or an increase in deductibles or co-pays.  Employers should be mindful of the types of situations that may trigger COBRA notice obligations.


Friday, April 24, 2015

The “litigation hold” – what it is and why you must do it.

When a dispute arises, the parties to it need to take action to safeguard evidence that relates to the dispute.  The parties need to place a “hold” on their normal destruction protocols so that routine document and data destruction won’t cause the loss of evidence relevant to the dispute. 

So, for example, if paperwork relating to a dispute is set to be shredded by the warehouse where it is stored, you need to contact the warehouse and instruct them to pull out and preserve that file.  Similarly, the relevant emails of those persons involved in the dispute must also be collected and stored.

Preserving evidence related to a dispute is both good practice and required under the law.  If you have a dispute with another, you will need evidence to support your position.  If you do not preserve the evidence in your possession regarding the dispute, you may not be able to prove you should prevail.  In addition to this practical aspect, both federal and state laws require you to preserve evidence when a dispute arises. 

The rules applicable to each situation differ, so it is critical that you consult with an attorney as soon as possible.  Failing to properly preserve evidence can have drastic consequences, up to and including the awarding of a judgment against you for failing to follow the applicable rules, making the need to consult with an attorney even greater.


Thursday, April 16, 2015

Internal Revenue Code Sections 6055 and 6056 - ACA Reporting and Compliance Overload for Multiemployer Health Plans

When you mention Internal Revenue Code (IRC) Sections 6055 and 6056 to many multiemployer health plan administrators and even contributing employers, they first respond, “We have a whole year before we have to address those regulations!”   The second thing that you may hear is that the contributing employers are not responsible for any reporting associated with IRC Section 6055 or 6056; rather it is the multiemployer plan sponsors that must complete the task.   Hearing both statements reinforces the complexity and misconceptions surrounding the latest mandates and responsibilities for multiemployer plans associated with the Affordable Care Act’s (ACA) latest dip into tax regulations.

The ACA requires two types of reports under Sections 6055 and 6056 of the IRC as a result of the regulations issued by the IRS in March, 2014.  The first report requires that employers, who provide “minimum essential coverage” (MEC) under IRC Section 6055, report on that coverage to every responsible individual that enrolls him or herself as well as his/her dependents in health care (Form 1095-B).  This Form 1095-B will be sent to employees similarly to the way that they receive W-2 Forms.  Once an employee (or a dependent that is covered under the employee’s insurance) can produce this Form 1095-B, they will be exempt from the ACA’s individual mandate tax.  In other words, the Form 1095-B is proof that a taxpayer has qualified health insurance.  This reporting requirement would be the responsibility of the Plan and in most cases with multiemployer plans, the Board of Trustees would be responsible for accumulating data for all of the months that employees are covered, along with the Forms 1095-B and sending them to the IRS, with a Form 1094-B for transmittal.  A checklist of items that must be included on the informational statements sent to employees and the IRS is clarified in the regulations.  The challenge may come to multiemployer plan sponsors once they endeavor to obtain all of this information needed on the 1095-B form which may be found at http://www.irs.gov/pub/irs-pdf/f1095b.pdf.

The second report, with Forms 1094-C and 1095-C filed with the IRS in compliance with IRC Sections 6055 and 6056, determines whether a large employer (more than 50 employees) owes tax to the IRS under IRC Section 4980H for failing to provide affordable health care coverage that provides minimum value to all of its full-time employees.  This burden of proof placed on employers is known as the “employer shared responsibility” (ESR).  This confirmation, that a multiemployer plan provides the required level of coverage to all full-time employees, must also be sent to full-time employees in the form of an annual statement, a Form 1095-C, just like the annual W-2’s and 1095-B statements. 

This is where the ESR report (and who should file it) complexity comes into play for multiemployer health and welfare plans.   It is the responsibility of the contributing employer to file their own reports; however, employers would need to obtain the proper information regarding their full-time employees coverage under the multi-employer plan to do so.  Alternatively, the plan sponsor may prepare the ESR reports on behalf of the contributing employers.  However, the plan sponsor may only file the reports for employees who are members covered under a collective bargaining group.  The contributing employer must file reports for non-bargaining employees.  Therefore, both multi-employer plan sponsors AND contributing employers must file Forms 1095-C and send statements as 1094-C when there are both bargaining and non-bargaining employees in a multiemployer plan. 

How long does a multiemployer plan have to get all of this data together if they take on the task for contributing employers?  What are the deadlines to get statements sent to members and reports sent to the IRS to avoid significant penalties?  Remember, all of this data applies to the 2015 calendar year.  In regards to the 1094-C and 1095-B statements sent to applicable employees, they must reach such employees by January 31, 2015.  Additionally, the MEC and ESR reports, described above, must meet a filing deadline of February 29, 2016 if filed by mail and by March 31, 2016 if filing electronically. 

Will plan sponsors, administrators and contributing employers have sufficient time to get their existing software lined up for IRC Sections 6055 and 6056 reports?  Should Boards of Trustees charge contributing employers for keeping these records even when they are not fully required by law to do so?  Will multi-employer plans be subject to liability if the contributing employers fail to provide them with accurate information regarding covered employees and full-time classifications?  Understanding the reports to be filed with the IRS and sent to plan members is a  good start to answering these types of questions for multiemployer plans. 


Wednesday, March 25, 2015

Internal Revenue Service Issues 2015 Cost-of-Living Adjustments for Retirement Plan Limits

On October 23, 2014, the Internal Revenue Service (“IRS”) announced cost-of-living adjustments to dollar limitations for items affecting tax-qualified retirement plans under the Internal Revenue Code (“Code”) in 2015. The announcement includes the following highlights for 2015: 

  • The elective deferral (contribution) limit for employees who participate in section 401(k), 403(b), most 457 plans, and the federal government’s Thrift Savings Plan is increased in 2015 from $17,500 to $18,000.
  • The catch-up contribution limit for the above listed plans for employees aged 50 and over is increased in 2015 from $5,500 to $6,000.
  • The limitation on the annual benefit under a defined benefit plan under Code Section 415(b)(1)(A) remains unchanged at $210,000.
  • The limitation for defined contribution plans under Code Section 415(c)(1)(A) is increased in 2015 from $52,000 to 53,000.

The following table sets forth the Code limits applicable to 401(k) plans, profit sharing plans, and defined benefit plans for 2015, with a comparison to such limits for 2013 and 2014. 

Limits under Applicable Code Section

2015

2014

2013

Annual Compensation - 401(a)(17)/404(l)

265,000

260,000

255,000

Elective Deferrals under 401(k) Plan - 402(g)(1)

18,000

17,500

17,500

Catch-Up Contributions under 401(k) Plan - 414(v)(2)(B)(i)

6,000

5,500

5,500

Annual Addition Limit for Defined Contribution Plans - 415(c)(1)(A)

53,000

52,000

51,000

Highly Compensated Employee Threshold - 414(q)(1)(B)

120,000

115,000

115,000

Annual Benefit Limit for Defined Benefit Plans - 415(b)(1)(A)

210,000

210,000

205,000

Key Employee Compensation Threshold - 416(i)(1)(A)(i)

170,000

170,000

165,000

Taxable Wage Base for Social Security Taxes

118,500

117,000

113,700

 


Wednesday, March 18, 2015

Lunch time excursions injuries usually not compensable

A recent case illustrated that just because you are working does not mean all your time is covered for workers compensation purposes.  A nurse who provided home care for the employers clients,  was injured in a car accident when he went to the pharmacy to get the clients prescription filled and went to have lunch while the pharmacy filled the order.  The accident took place on the way back from lunch to the pharmacy.  The Court said that even though the claimant had discretion when to take lunch the location of the restaurant away from the pharmacy constituted a “personal frolic” and therefore the injury did not occur in the course of employment.    


Monday, March 9, 2015

Equal Employment Opportunity Commission Issues - Guidance on Pregnancy-Related Benefits

On July 14, 2014, the Equal Employment Opportunity Commission (“EEOC”) issued new enforcement guidance pertaining to pregnancy-related benefits under a group health care plan.  The new guidance appears in an updated chapter of the EEOC’s enforcement manual and a related set of questions and answers.  Covering developments from the past 30 years, the guidance discusses the requirements of the Pregnancy Discrimination Act and, of particular import, also addresses the application of the Americans with Disabilities Act to pregnancy-related impairments.

Summary.  The new guidance explains when an employer’s policies affecting pregnant employees might violate federal law.  Among other topics, the guidance addresses the rights of pregnant employees under employer health care plans, fringe benefit programs, and other benefit plans.

The guidance emphasizes that employers offering group health care coverage must—

  • include coverage of pregnancy, childbirth, and related medical conditions, and
  • apply the same terms to pregnancy-related costs that they apply to other costs.

An express exception in the Pregnancy Discrimination Act permits employers to refuse to cover the cost of abortions, except in cases in which the life of the mother would be endangered by a full-term pregnancy.  To the extent that medical complications arise from an abortion, however, the group health care plan must cover the cost of treating the complications.

Prescription Contraceptives.  The new guidance also confirms that the Pregnancy Discrimination Act requires group health plans to cover prescription contraceptives to the same extent that the plans cover prescription drugs, devices, and services designed to prevent medical conditions other than pregnancy.  The guidance acknowledges that employers with religious objections to contraceptives may fall within statutory or constitutional exceptions.  It does not explain, however, to what extent these exceptions apply under the Pregnancy Discrimination Act.  In Burwell v. Hobby Lobby Stores, Inc., the United States Supreme Court ruled that the Patient Protection and Affordable Care Act’s contraceptive mandate violated the Religious Freedom Restoration Act as applied to closely held, family for-profit corporations whose owners had religious objections to providing certain types of contraceptives.

The new EEOC guidance on contraceptive coverage is consistent with the position that the EEOC has taken in individual enforcement actions against employers.  The issue concerning mandatory contraceptive coverage in health care plans has been litigated in federal and state courts, with mixed results.  Although the Patient Protection and Affordable Care Act (“ACA”) has largely resolved the issue by requiring non-grandfathered group health care plans to cover most contraceptive methods and services as a form of preventive care, the guidance does not specifically address its impact on plans that are grandfathered under the ACA and thus exempt from the ACA’s preventive-care mandate.

Some commentators have taken the position that because the Employee Retirement Income Security Act of 1974 (“ERISA”) does not preempt other federal laws relating to employee benefit plans, laws like the Pregnancy Discrimination Act that, in accordance with Title VII of the Civil Rights Act of 1964, provide employees with protection from pregnancy-based discrimination would not be preempted by ERISA.  Accordingly, any guidance issued by the EEOC on pregnancy-based discrimination under the Pregnancy Discrimination Act would apply to all self-funded ERISA-governed health care plans, whether grandfathered or non-grandfathered.

Key Takeaways.  Plans that offer prescription benefits should be reviewed to determine whether the benefits that are offered under the plan are consistent with the new EEOC guidance.  In particular, the plan’s prescription drug program should be reviewed to determine whether prescription contraceptives are covered to the same extent as prescription drugs, devices, and services that are used to prevent the occurrence of medical conditions other than pregnancy.


Wednesday, October 1, 2014

United States Department of Labor Issues Updated Guidance on Fiduciary Duty to Locate Missing Participants

One of the perennial problems that plan administrators of defined contribution plans face is the disposition of accounts being held for participants who are owed benefits but cannot be located (referred to as “missing participants”).  On August 14, 2014, the United States Department of Labor (“DOL”) issued updated guidance regarding a fiduciary’s duty to locate missing participants and beneficiaries when making distributions from terminated defined contribution plans. The new DOL guidance was prompted by the termination of well-established letter-forwarding programs that had been developed and used for many years by the Internal Revenue Service and the Social Security Administration to locate missing participants.  Although the new DOL guidance is aimed at terminated defined contribution plans, the guidance has relevance to non-terminated defined contribution and defined benefit plans that are faced with the problem of finding missing participants.

Searching for Missing Participants.  According to the DOL guidance, a fiduciary must make a reasonable effort to locate missing participants so that the fiduciary can implement directions from the participant or beneficiary regarding plan distributions.  Reasonable expenses incurred in the search may be charged to missing participants’ accounts.

The guidance provides four search methods that the fiduciary is required to use to find a missing participant.  Other methods may be required if the missing participant’s account balance is large enough to warrant additional expense.  The required search methods are:

1.         Use Certified Mail.  The fiduciary should send a notice to the participant’s last known address using certified mail.  The DOL has previously provided a model notice that can be used for such a mailing.  Other forms of notice can also be used.

2.     Check Related Plan, Fund Office, and Employer Records.  It is possible that more up-to-date contact information about a missing participant’s whereabouts is available through other sources, including the fund office for a Taft-Hartley plan, the participant’s former employer, or the administrator of a related plan.  The fiduciary should request that the fund office, the former employer, or the administrator, as applicable, search its records for a more current address for the participant.  According to the DOL, if there are privacy concerns, the fiduciary engaged in the search may request that the source contact the missing participant, or forward a letter to the participant, on the plan’s behalf.

3.         Check with Designated Plan Beneficiary. The third method is for the fiduciary to try to identify and contact any individual that the missing participant has designated as a beneficiary (e.g., spouse, children, etc.) to find updated contact information for the missing participant.  Again, if there are privacy concerns, the fiduciary may request that the designated beneficiary contact the missing participant, or forward a letter to the participant, on the plan’s behalf.

4.   Use Free Electronic Search Tools.  A fiduciary must make reasonable use of Internet search tools that do not charge a fee to search for locating a missing participant.  Such online services include Internet search engines, public record databases (such as those for licenses, mortgages and real estate taxes), obituaries, and social media.

If these four search methods are not successful in locating the missing participant, the fiduciary must consider the use of additional search methods, including Internet search tools, commercial locator services, credit reporting agencies, information brokers, investigation databases, and other services that may involve charges.  Whether to use additional search methods is a fiduciary decision that should take into account the size of the benefit and the amount of the additional expense.  All decisions made the plan administrator to locate participants whose whereabouts are unknown and distribute their accounts should be recorded in written or electronic form so that the plan administrator can demonstrate to the DOL’s satisfaction that it has satisfied its fiduciary duty to locate the missing participants.  The DOL guidance underscores that such decisions are fiduciary decisions and not merely administrative decisions.

Key Takeaways.  Although the new DOL guidance regarding missing participants is intended for use by fiduciaries of terminated defined contribution plans, the guidance can be equally useful to the administrators of non-terminated defined contribution and defined benefit plans.  Plan fiduciaries now have an obligation to use the DOL’s four required steps to locate missing participants.  A fiduciary’s decision to follow these steps and, if warranted, use additional search methods is a matter of fiduciary duty, and not merely an administrative decision.

If you have any questions or concerns regarding this communication, please do not hesitate to call Allotta | Farley Co., L.P.A. at (419) 535-0075 or email megarner@allottafarley.com.


Friday, September 26, 2014

IRS Releases Draft Forms for Reporting Health Coverage

The Internal Revenue Service has released draft forms that employers will use to report the health coverage they offer their employees. The draft Form 1095–B, Health Coverage, and Form 1095–C, Employer-Provided Health Insurance Offer and Coverage, were posted to the IRS's website July 24, 2014.

Form 1095–B collects information under tax code Section 6055, which under the Affordable Care Act (ACA) sets the standards for reporting information on whether plans meet minimum essential coverage.

Form 1095–C falls under the jurisdiction of Section 6056, which lays out the requirements that must be followed by employers with the equivalent of at least 50 full-time employees to report whether they offer employees coverage that meets minimum value and affordability standards.

The reporting relates to the ACA's employer mandate, which, when it fully goes into effect, will require these employers to offer such coverage or potentially face penalties.

The IRS released a the following statement:  “In accordance with the IRS' normal process, these draft forms are being provided to help stakeholders, including employers, tax professionals and software providers, prepare for these new reporting provisions and to invite comments from them. We anticipate that draft instructions relating to the forms will be posted to IRS.gov in August. Both the forms and instructions will be finalized later this year,”

The IRS also released draft versions of two related forms, Form 1094–B, Transmittal of Health Coverage Information Returns, and 1094–C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns.

Comments on the draft version of the forms can be made on the IRS website at http://www.irs.gov/uac/Comment-on-Tax-Forms-and-Publications.


Thursday, July 31, 2014

Not All Injuries Need Medical Records to Prove the Claim

 A recent Ohio case provided a reminder that not all injuries require proof from a medical provider that injury was caused by the accident in question.  The First District Court of Appeals reiterated a long held doctrine that when the injury and subsequent physical disability involves questions which are matters of common knowledge, medical evidence is not necessary for a jury to decide the case.  The case in question involved a man who injured his eye when a piece of concrete hit him while using a jackhammer.   The Court said “You don’t need a doctor to tell you that a cut is likely to result if a piece of concrete, displaced by a jackhammer, flies up, breaks ones glasses and hits the eye.”  Even so medical evidence and testimony is always used, unless a mistake occurs, because what may be common knowledge to you might not be to the court hearing the case.  


Friday, July 11, 2014

QDIA--A Well-Guarded Parking Lot for Plan Participants and a Safe Harbor for Trustees

While many fund trustees, fiduciaries and investment managers spend inordinate amounts of time pouring over investment returns, diversification strategies and risk matrices to find the optimal rate of return for their defined contribution plans (401(k) and profit sharing plans), participants in these plans struggle to make investment decisions. When faced with the opportunity to self-direct their 401(k) or profit sharing plan contributions, they hesitate.  In fact, many participants experience such a huge sense of inertia that they abdicate their right to elect investments of their plan balances to the plan sponsor.  Such inaction then places an additional fiduciary duty on plan trustees and committees to protect the retirement balances of these participants from a significant risk of loss.

Before the Pension Protection Act (PPA) in 2006, lack of participant involvement commonly meant that plan sponsors “parked” participant account balances in default investments until they felt comfortable making their own choices.   These default investments, while they were in low-risk categories,  garnered lower rates of return that often did not even keep up with inflation. Consequently, retirees’ account balances were inadequate to support them in their golden years.  As part of the PPA, the Department of Labor (DOL) addressed this problem with regulations under section 404(c)(5) of the Employee Retirement Income Security Act (ERISA), creating the qualified default investment alternative (QDIA).  The QDIA now enables fiduciaries to implement more aggressive investments when participants fail to make their own investment elections without violating their fiduciary obligations. 

But don’t assume that the DOL gave plan trustees and committees total freedom when choosing QDIAs as part of their plan’s investment menu. Quite the contrary is true due to the narrowly defined guidelines and options specified in  ERISA’s Section 405(a) regulations.  Among other restrictions, only three investment options are allowable for long-term QDIAs: target-date funds (TDFs), managed accounts and balanced funds. Each has its advantages and disadvantages with different costs, reporting issues and levels of customization for participant groups.  However, the main goal for trustees and committees when choosing a QDIA should be diversification to minimize the risk of large losses to participants’ accounts. 

To reinforce their due diligence in making QDIA choices, many plan trustees request unofficial approval letters from qualified legal counsel to ensure that a QDIA meets the parameters defined in the ERISA regulations and fits the description of either a TDF, a balanced fund or an appropriately individually managed account.  They get guidance on their process in communicating their QDIA option to participants and beneficiaries.  Formal review from legal counsel may provide trustees with proof that they did their  fiduciary “homework” in choosing a QDIA while remaining compliant with current regulations and making decisions for the exclusive purpose of providing benefits for participants and beneficiaries. 

Ultimately, when choosing a QDIA option, plan sponsors must consider several questions to determine which selection best fits their plan participants:

  • What is the aggregate age of our workforce or participant group?
  • What is the average age of retirement for our workforce?
  • Is there a general risk tolerance that applies to our workforce?
  • Is our QDIA selection designed to outpace inflation?
  • Does our QDIA selection consistently insulate participant accounts from risk of large losses with a diversification strategy?

By navigating these questions, focusing on guidelines set out by section 404(c)(5) of ERISA and consulting legal counsel to ensure that the criteria for QDIA status are met, trustees will have fewer allegations from participants that their retirement balances were defaulted or “parked” in inappropriate investment vehicles.  


Tuesday, June 24, 2014

Make sure your claim is filed!

Two times within the past week I have been contacted about a work related injury that was several weeks to a couple months old.  When I asked what had been done by the BWC or the self-insured employer regarding processing the claim the injured worker had no idea whether they even had a claim that was established.  The first thing to check out is making sure that the BWC has gotten the claim form and that it has started gathering the information for granting the claim.  A call to 1-800-(ohiobwc) can ascertain if a claim has been filed and what your is your claim number.  If the employer is self-insured you should ask their Workers Compensation Administrator or (if they don’t have one) their Third Party Administrator (the firm they pay to handle these claims) what is being done with the claim.  Without knowledge of where your claim is in the process you can not provide important information to your doctors, therapists, etc who may need this information in order to know what and with whom to file any paperwork to allow them to help in the treatment of your injury.  


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