7. COBRA Premium Grace Period Extension What
Advise COBRA Qualified Beneficiaries of grace period extension to 60-days (if applicable). The COBRA premium grace period is either 30 days or the grace period of the employer, if longer. This means that if the employer has a longer grace period, so do their COBRA Qualified Beneficiaries.
ASAP, but prior to April 30, 2020 which would be the normal premium deadline for April premiums.
This assumes the carrier has approved premium extension as requested by California Department of Insurance (DOI). This was a request made by DOI, not a requirement, so while adoption is widespread, it is not necessarily universal. Self-funded plans must make the decision whether to offer the grace period extension or not. It should be noted that this guidance was made by the DOI, and similar language has not been issued by the DMHC which governs HMO plans. Many plans are following suit on this premium extension, but it is important to confirm whether your plans have adopted this grace period extension.
Administrative Items 8. Set up New Payroll Codes What
Coordinate with payroll vendor to set up payroll codes for tracking paid sick time and paid family leave. Because employers need effective reporting of these payments in order to take tax credits to offset payments for paid leaves. Prior to the first payments being paid to employees. That typically means codes must be set up prior to the first payroll run after April 1, 2020 (the effective date of the law). Most payroll companies are quickly preparing new codes to accommodate the needed infrastructure. HR and payroll departments will need to develop new procedures and coordinate communication in terms of how these leaves are reported by employees and tracked in company systems.
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