Recent guidance from the Department of Labor (“DOL”), Health and Human Services (“HHS”) and Treasury (the “Departments”) provides limited enforcement relief from the summary of benefits and coverage (“SBC”) disclosure rules during the COVID-19 crisis for employers to comply with the CARES Act or to add other benefits to their group health plans. Dickinson Wright’s …
Expired State Identity Documents Temporarily Accepted for Form I-9 List B and the Case-by Case Remote Form I-9 Completion Risk
U.S. Citizenship and Immigration Services (USCIS) recently issued a follow-up Question and Answer sheet (Q&A Sheet) to the March 20 announcement of the U.S. Department of Homeland Security (DHS) related to a limited relaxation to physical proximity requirements associated with Form I-9 completion due to COVID-19. While the acceptance of an expired state identity document …
CRITICAL COVID-19 GUIDANCE FOR CERTAIN FOREIGN WORKERS
The ever-changing impact of the evolving COVID-19 pandemic is making it extremely difficult for employers to plan what to do with their foreign worker populations right now. DW Immigration stands ready to help! Here below we summarize some critical pieces of immigration information from the various government agencies and our related guidance, as it stands …
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Summary of Employee Benefits Provisions in CARES Act (as passed by U.S. Senate)
On March 25, 2020, the Senate passed the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, as a follow-up to the Families First Coronavirus Response Act. The Act contains a number of employee benefits related provisions to address the COVID-19 emergency. The House of Representatives intends to take up the legislation on March 27, 2020. …
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Michigan Governor Issues Stay-At-Home Order
On Monday, March 23, 2020, Michigan Governor Gretchen Whitmer issued a statewide stay-at-home order to fight the ongoing coronavirus outbreak. The executive order, effective at 12:01 am on Tuesday, March 24, 2020, will continue for at least the next three weeks. Individuals may only leave their home or place of residence under very limited circumstances. …
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DHS Announces Remote I-9 Completion and Suspension of Audit Responses due to COVID-19
With all of the dark news surrounding COVID-19, the Department of Homeland Security (DHS) deserves a “thank you” from employers for their logical announcement related to Form I-9 compliance issues on March 20. The main points in the announcement are outlined below: Remote Completion of Section 2 of Form I-9 For completion of Section 2 …
High Deductible Health Plans and Expenses related to COVID-19
Many of the nation’s largest insurers have announced that they will be waiving the deductible or other cost-sharing for testing or other expenses related to the 2019 Novel Coronavirus (“COVID-19”). Plan sponsors that offer coverage to employees through a high deductible health plan (“HDHP”) asked whether this waiver would affect the health plan’s status as …
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Update on Coronavirus: Travel Restrictions and Quarantine Now Extended to Certain Travelers from Iran
The Department of Homeland Security (“DHS”) has expanded its travel ban concerning the Coronavirus Disease 2019 (COVID-19) to bar certain foreign national travelers who have been physically present in Iran within the last 14 days from entering the U.S. The expanded ban took effect on March 2, 2020. The travel ban does not apply to …
CORONAVIRUS (COVID-19) PRECAUTIONS FOR EMPLOYERS
It is now impossible to avoid the reality that the coronavirus disease 2019 (COVID-19, the “coronavirus”), is a “public health emergency of international concern,” according to the Centers for Disease Control and Prevention (“CDC”).[i] As of publication, the coronavirus is not spreading in the community in the United States.[ii] The CDC reports that the immediate …
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In Surprising Memo, IRS Concludes There is No Statute of Limitations on Affordable Care Act “Pay or Play” Taxes: What Steps Employers Should Take Now
In an unexpected memo from the IRS, the Office of Chief Counsel has concluded that the filing of Affordable Care Act (“ACA”) returns does not start the statute of limitations on the Employer Shared Responsibility Payments (“ESRP”) that may be owed by employers with 50 or more full-time (or equivalent) employees. ESRP is also commonly …