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Employer Insurance Premium Payment Grace Periods & Premiums Returned to Employers Inadvertent ERISA Issues

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During this pandemic, many employers are having to curtail operations and are going through the difficult process of finding cost-saving measures because of the sudden reduction in revenue caused by the various COVID-19 related state and local government orders.
Many carriers are allowing, and some states are requiring insurance policies to remain in force even if premiums are not paid timely. Also, some fully insured carriers, knowing employees have not been able to utilize their insurance due to non-emergency services being closed (e.g. dental exam), may be returning premiums paid to employers or giving a reduction in the monthly premium as a good faith gesture.

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