Target: Vaccine Incentive Webinar
Join Brown & Brown on Wednesday, September 15th at 9:00am PST for a webinar on vaccination incentives and wellness plans. Vaccine incentives for employees and health plan participants have made headlines recently. Ultimately, most vaccine incentive programs will have to comply with the guidelines created for wellness plans, regardless of whether the incentive is a reward or a surcharge. Join us as we discuss the fine points of this issue, with topics including:
- HIPAA nondiscrimination rules
- Whether the ADA applies
- Religious objections
- The ACA’s Employer Mandate and affordability
- The pre-tax rules under §125
- Mid-year incentive implementation
Target: Partnership Access Line Fund Assessment
Reminder that last month we let you know about the new Partnership Access Line (PAL) fees that would be coming for any employer that offers a health plan in WA. The assessment will be based on quarterly numbers of covered lives. Plans will be required to submit covered life reports within 45 days after the end of each quarter, with the first reported quarter being the third quarter of 2021 (the period of July 1 to September 30, 2021). The first payment is due on or before November 14, 2021. While the rate has not yet been determined, but the 2021-2022 fiscal year funding target for the WAPAL Fund is expected to be $3,663,300. The cost per covered life under each assessed entity has been estimated to be approximately $0.65.
Note that out-of-state employers who provide health care to Washington residents will be required to pay the assessment.
A company called KidsVax has been chosen to act as the third-party administrator to calculate and administer the assessments. KidsVax has established a website to provide important information for assessed entities and payers, including an overview and FAQ of the assessment program, training materials, instructions regarding how to register and how to complete the covered lives reports, email alert registration, and contact information.
For fully-insured health plans, the carrier will be responsible for compliance with the PAL assessment. For self-insured health plans, the employer will be responsible for compliance with the PAL assessment. Employers sponsoring self-insured plans should coordinate with their TPAs to determine whether they will provide any assistance in handling the WAPAL Fund assessment. The WAPAL Fund’s official commencement notice and summary of compliance obligations can be found here. Additional information can be found on the following websites:
- Washington State website for PAL assessment
- Washington State website FAQs
- WAPAL Fund website
- WAPAL Fund resources for assessed entities and payers
Brown & Brown has targeted these valuable resources to help you and your employees through the COVID-19 pandemic
Please don’t hesitate to reach out to your Brown & Brown team with any questions, thank you.