Washington Governor Jay Inslee, on March 30, 2022, signed into law amendments to the state’s Equal Pay and Opportunity Act (EPOA Amendments), which soon will require most Washington employers to include pay ranges and benefits information in their job postings. The EPOA Amendments become effective on January 1, 2023. Because the EPOA Amendments only define
Other Employer Considerations
Contractual Considerations for Self-Funded Group Health Plan Sponsors in 2022
In our January 2022 update, we discussed new federal requirements that group health plans should pay close attention to in 2022. The sponsor of a self-funded plan will need to work closely with its legal counsel, benefits consultant, and administrative services only (ASO) provider or other third-party administrator (collectively, TPA) to modify its plan…

Washington Legislature Amends WA Cares Fund, Delays Premium Collection until July 2023
On January 27, 2002, Washington Governor Jay Inslee signed House Bills 1732 and 1733 into law, officially delaying the assessment of WA Cares Fund premiums until July 1, 2023. As a result, WA Cares Fund benefits will not be available until July 1, 2026. These delays give state lawmakers additional time to resolve key issues…

Ringing in the New Year: Key Developments for Health Plan Sponsors
There are many new and expanding legal requirements for group health plans and issuers of group health plan coverage to pay attention to this year. Many of these requirements were enacted as part of the Consolidated Appropriations Act of 2021, which passed in December 2020. This update describes the key legal requirements that we are…
Washington Governor Attempts to Clarify WA Cares Fund Premium Collection
Today, Washington Governor Jay Inslee released a statement clarifying his earlier statement about delaying the assessment of WA Cares Fund premiums. (Our earlier blog entry is here.) In today’s clarification, the Governor appears to be saying that employers still have a choice to make about whether to collect and remit WA Cares Fund premiums,…
Washington State Pauses Collection of WA Cares Fund Premium Assessments, Employers Should Too

See our December 23, 2021 update to this alert here: Washington Governor Attempts to Clarify WA Cares Fund Premium Collection | Employee Benefits (perkinscoiebenefitsblog.com)
On December 17, Washington Governor Jay Inslee, Senate Majority Leader Andy Billig, and House Speaker Laurie Jinkins issued a joint statement that included the Governor’s intention to direct the State’s Employment…
HHS Restores Transgender, LGBTQ+ Health Care Protections

The Department of Health and Human Services has stated that it will restore transgender and LGBTQ+ health care protections. Under the Trump Administration, HHS had defined the term “sex” narrowly to mean gender assigned at birth. This had the consequence of excluding transgender and other LGBTQ+ individuals from protection against discrimination in health care. The…
IRS Temporarily Permits E-signature of 83(b) Elections
On April 15, 2021, in response to the ongoing COVID-19 situation, the U.S. Internal Revenue Service (IRS) issued a temporary deviation from the handwritten signature requirement for a limited list of tax forms, including elections under Section 83(b) of the Internal Revenue Code, allowing taxpayers and representatives to use electronic or digital signatures when signing…
Washington Employers Must Act Now to Stay Ahead of New Long-Term Care Act
In 2019, Washington passed the first law in the nation requiring employees to fund a state-operated long-term care insurance program. The program, codified at RCW 50B.04 and set to begin on January 1, 2025, will be funded by an uncapped payroll tax starting at 0.58% on all employee compensation beginning January 1, 2022.
Although changes…
Employer Responsibilities Under the ARPA COBRA Subsidy
The American Rescue Plan Act of 2021 (ARPA) includes a 100% federal subsidy of COBRA premiums (including the up-to-2% administrative fees) during the period of April 1, 2021, through September 30, 2021. The subsidy applies to group health coverage typically subject to COBRA, except for health flexible spending accounts. This update summarizes the ARPA’s COBRA …