Sarah Raaii
Subscribe to Sarah Raaii's PostsSarah G. Raaii focuses her practice on employee benefits and matters related to health care reform, data privacy and HIPAA compliance, executive compensation, and health and welfare, cafeteria, 401(k), 403(b) and pension plans. Read Sarah Raaii's full bio.
Agencies Clarify How Employers Can Charge COVID-19 Vaccine Premium Incentives
By Sarah Raaii and McDermott Will & Emery on Nov 2, 2021
Posted In Employee Benefits, Employment, Health and Welfare Plans
On October 4, 2021, the US Departments of Labor, Treasury, and Health and Human Services issued guidance regarding the application of the Health Insurance Portability and Accountability Act (HIPAA) wellness rules to vaccine-related premium surcharges and discounts, clarifying that employers may charge vaccine premium incentives if they adhere to the requirements of activity-only health-contingent programs....
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IRS Provides Further Guidance on COBRA Election and Payment Deadlines
By Sarah Raaii and McDermott Will & Emery on Oct 27, 2021
Posted In Employee Benefits, Employment, Health and Welfare Plans
In Notice 2021-58, the Internal Revenue Service clarified that the one-year tolling relief periods for Consolidated Omnibus Budget Reconciliation Act (COBRA) elections and initial premium payments run concurrently, not consecutively. This means that a qualified beneficiary generally will have only one year of total disregarded time for the election and initial payment periods. Read more...
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How to Apply the IRS’s COBRA Premium Subsidy Guidance
By Jacob Mattinson, Sarah Raaii, Teal Trujillo and McDermott Will & Emery on Jun 9, 2021
Posted In Employee Benefits, Employment, Health and Welfare Plans
On May 18, 2021, the Internal Revenue Service (IRS) issued much-anticipated Notice 2021-31 (the Notice) regarding the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy provisions of the American Rescue Plan Act of 2021 (ARPA). Under ARPA, a 100% COBRA premium subsidy and additional COBRA enrollment rights are available to certain assistance eligible individuals (AEIs)...
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IRS Provides Additional COVID-19 Relief for Cafeteria Plans
By Jacob Mattinson and Sarah Raaii on Apr 13, 2021
Posted In Employee Benefits, Health and Welfare Plans
On February 18, 2021, the Internal Revenue Service (IRS) issued clarifying guidance on the temporary special rules for health flexible spending arrangements (FSAs) and dependent care assistance programs (DCAPs). This provides welcome guidance regarding the application of cafeteria plan relief provided by the Consolidated Appropriations Act (CAA). Access the article.
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COVID-19 Relief Bill Offers COBRA Reform and Temporarily Increases DCAP Maximum
By Jacob Mattinson and Sarah Raaii on Mar 25, 2021
Posted In Employee Benefits, Health and Welfare Plans, Privacy and Data Security
On March 11, 2021, President Joe Biden signed the American Rescue Plan Act of 2021 (ARPA) providing Consolidated Omnibus Budget Reconciliation Act (COBRA) reform provisions and an increase in Dependent Care Assistance Program (DCAP) maximum deferrals. While details from the agencies are forthcoming, here is an overview of these provisions of the ARPA. Access the...
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EEOC Proposes New Rules on Wellness Programs
By Jacob Mattinson and Sarah Raaii on Jan 26, 2021
Posted In Employee Benefits, Health and Welfare Plans, Privacy and Data Security
On January 7, 2021, the Equal Employment Opportunity Commission (EEOC) issued proposed guidance regarding employer-sponsored wellness programs and the level of incentives employers may offer employees who participate in these programs in the form of two proposed rules. On January 20, 2021, the Biden administration ordered agencies to immediately withdraw most unpublished rules, including the...
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Consolidated Appropriations Act: Health and Welfare Benefits Provisions
By Jacob Mattinson and Sarah Raaii on Jan 20, 2021
Posted In Employee Benefits, Health and Welfare Plans
The Consolidated Appropriations Act (the Act) was signed into law by the president on December 27, 2020, and includes significant health and welfare benefits provisions that affect group health plans and health insurance issuers. The Act is the most comprehensive single piece of legislation to impact group health plans since the Affordable Care Act. Access...
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Agencies Issue Final Employer Healthcare Price Transparency Rule
By Jacob Mattinson and Sarah Raaii on Dec 10, 2020
Posted In Employee Benefits, Health and Welfare Plans
On October 29, 2020, the US Departments of Health and Human Services, Labor, and Treasury (collectively, the Departments) issued the Transparency in Coverage final rule (the Rule), along with a fact sheet, setting forth requirements for group health plans and health insurance issuers to disclose cost-sharing information upon request to participants, as well as additional...
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