Your Monthly
Newsletter from Integrated Benefit Solutions
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September 2020
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Medicare Part D Notices Are Due Before Oct. 15, 2020
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Each year, Medicare Part D requires group health
plan sponsors to disclose to individuals who are eligible for
Medicare Part D and to the Centers for Medicare and Medicaid
Services (CMS) whether the health plan’s prescription drug
coverage is creditable.
Plan sponsors must provide the annual disclosure notice to
Medicare-eligible individuals before Oct. 15, 2020—the start date
of the annual enrollment period for Medicare Part D. CMS has
provided model disclosure notices
for employers to use.
This notice is important because Medicare beneficiaries who are
not covered by creditable prescription drug coverage and do not
enroll in Medicare Part D when first eligible will likely pay
higher premiums if they enroll at a later date. Although there
are no specific penalties associated with this notice
requirement, failing to provide the notice may be detrimental to
employees.
Employers should confirm whether their health plans’ prescription
drug coverage is creditable or non-creditable and prepare to send
their Medicare Part D disclosure notices before Oct. 15, 2020. To
make the process easier, employers often include Medicare Part D
notices in open enrollment packets they send out prior to Oct.
15.
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Preparing for an Unprecedented Open Enrollment
Period
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Open enrollment following the COVID-19 pandemic
will be unlike any other in recent memory. Many organizations are
still trying to recover from extended closures and maintain safe
working environments—open enrollment is the last thing on their
minds. Yet, procrastinating on enrollment planning can actually cause more issues than it solves.
Open enrollment isn’t always a clear-cut process. Something that’s successful for one organization won’t
necessarily work for another. Employers should review the
following strategies and consider how similar initiatives might
improve their own open enrollment efforts:
- Confer with management about
any operational restrictions that may influence open
enrollment (i.e., if in-person staff is limited within the
workplace, in-person enrollment is likely not an option).
- Meet with stakeholders to
solidify what the enrollment process will look like,
including whether it will be entirely virtual, in-person
with social distancing or some other combination of
strategies.
- Debrief managers early in
the enrollment process, and
encourage them to communicate regularly to employees about
the upcoming open enrollment.
- Inform all stakeholders
(anyone to whom an employee may reach out about open
enrollment questions) about the enrollment process. They
should know where to find the answers to any topic,
including:
- Benefits effective date
- Enrollment period
- What happens to furloughed
employees’ benefits
- How plan contributions work
during extended closures
- Communicate to employees
about open enrollment through multiple channels. Consider
using videos, mail-home postcards, PDFs
and other materials to ensure employees have all the
information they need.
Preparation
will be the key factor for a successful open enrollment this
year. Employers should talk to stakeholders early and prepare to
answer any employee questions. Employees will need to know
exactly how they will be enrolling, when enrollment is happening
and where they can find help. Solidifying this information early
will help keep everyone on the same page.
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DOL Issues Guidance on Tracking Hours of Work for
Remote Employees
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On Aug. 24, 2020, the U.S. Department of Labor
(DOL) issued Field Assistance Bulletin
No. 2020-5 to remind employers of their obligation to
accurately account for the number of hours their employees work
away from the employer’s facilities. While the bulletin was
issued in response to the high number of employees working
remotely because of the COVID-19 pandemic, the DOL is also
reminding employers that the underlying principles apply to other
telework or remote work arrangements.
Compensable
Time
The federal Fair Labor Standards Act (FLSA), requires employers
to compensate their employees for all hours of work. Compensable
time includes any hours an employee is requested or allowed to
work, including telework or remote work.
For remote work situations, the bulletin clarifies that
compensable time includes any time during which the employer
knows or has reason to believe work is being performed,
regardless of whether the work was authorized or requested.
Employer
Obligations
As a result, under the FLSA employers have an obligation to track
the number of hours their employees work. For this reason,
employers must provide reasonable procedures for employees to
report any scheduled and unscheduled hours of work. However, the
DOL is of the opinion that “if an employee fails to report
unscheduled hours of work through a reasonable process, the
employer is not required to undergo impractical efforts to
uncover unreported hours of work.”
Finally, the bulletin emphasizes that employers bear the burden
of preventing an employee from completing unauthorized or
unwanted work.
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How to Make Your Job Posting Stand Out
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Filling a job vacancy is a big task. Unfortunately,
you get only one chance to make a first impression, and the job
posting is often your very first contact with a potential
employee. But how do you make your job posting stand out above
the rest? Watch the video below to learn five fast tips to make
your job posting stand out.
For additional HR guidance, visit our Human
Resources section.
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