Our April Dish is brought to you by our very own Cindy Contreras!
Cindy joins Hierl as our Administrative Assistant. With her degree in Management/Human Resources and Finance, she’s a perfect fit for our office and our clients.
At home, Cindy enjoys spending time with her husband and 3 children. She thoroughly enjoys watching her children grow and experience the wonders of life. Together, they enjoy outdoor activities like bicycling and camping, as well as indoor activities such as visiting the library and cozying up for a nice movie.
When it comes to eating out, Cindy enjoys a local favorite that features authentic Mexican food that’s truly made with love.
“Mi Casa is small little restaurant owned by people who really care about making good food. My favorite meal is the camaron suizos. Shrimp sautéed with bacon, onions and mushrooms in a cheese sauce. So delicious!”
At home, Cindy enjoys making Mexican comfort foods and one of her favorites is Arroz Con Leche (Mexican Rice Pudding). Be sure to check out the delicious recipe below!
Arroz Con Leche (Mexican Rice Pudding)
“It’s a dessert that can be served after lunch or dinner, but will also make a great treat for your children during breakfast time. Give it a try! I guarantee you won’t be disappointed!”
Here’s what you’ll need:
Let’s get started:
A dessert that can be served at any time of the day is a MUST! Can’t wait to try it out Cindy!
Our March Dish is brought to you by our very own Patty McBride!
Patty works as our Employee Benefits Service Agent. Her passion for her work shines through in her attention to detail and organizational skill throughout the quoting process!
When it comes to eating out, Patty enjoys the authentic Mexican cuisine found at Casa del Tequila. “Their Chicken Tinga or the Chicken Fajitas are [my] favorite with a margarita! They have salsa and guacamole prepared tableside!” Need Directions?
For home cooking, Patty enjoys a family recipe passed down from her great grandmother. “We always look forward to this when the garden green beans are in abundance. From my mother, her grandmother.”
Grandma’s Fresh Green Bean Dish
“Grandma was one of those natural cooks who never measured, knew just what to add and when things were right. If you can cook without specific measurements treat yourself to this family favorite of many generations.”
Regardless of which recipe you decide to cook, it’s bound to taste delicious and it times perfectly with Saint Patrick’s Day! Thanks Patty!
Updated March 2017 by our partners at United Benefits Advisors.
In the fall of 2013, the Department of Health and Human Services (HHS) announced a transitional relief program that allowed state insurance departments to permit early renewal at the end of 2013 of individual and small group policies that do not meet the “market reform” requirements of the Patient Protection and Affordable Care Act (ACA) and for the policies to remain in force until their new renewal date in late 2014.
On March 5, 2014, HHS released a Bulletin that extended transitional relief to permit renewals as late as October 1, 2016, allowing plans to remain in force until as late as September 30, 2017. On February 29, 2016, HHS released another Bulletin to permit renewals until October 1, 2017, with a termination date no later than December 31, 2017. On February 23, 2017, HHS released its Insurance Standards Bulletin Series, in which it re-extended its transitional policy. States may permit issuers that have renewed policies under the transitional policy continually since 2014 to renew such coverage for a policy year starting on or before October 1, 2018; however, any policies renewed under this transitional policy must not extend past December 31, 2018.
The primary market reforms are the requirements that policies include the 10 essential health benefits, be valued at the “metal levels” (platinum 90%, gold 80%, silver 70%, or bronze 60%), and be community rated (which means that rates may only be based on age with a 3:1 limit, smoking status with a 1.5:1 limit, rating area and whether dependents are covered). Under the ACA, all non-grandfathered group health plans must ensure that annual out-of-pocket cost sharing (for example, deductibles, coinsurance and copayments) for in-network essential health benefits does not exceed certain limits; in February 2015, HHS clarified that the out-of-pocket limits apply to each individual, even those enrolled in family coverage
Not all existing policies automatically may or will be renewed. In addition to permission from the federal government, both the state insurance department and the insurance company must agree to renew these non-compliant policies. A list of state decisions as of March 2016 is available at healthinsurance.org.
States and insurers have the option to include some of the market reform requirements that the federal government says may be disregarded. States had the option to allow renewals of individual policies only, small group policies only, or both types of policies, and to allow this for 2015 only or for both 2015 and 2016. In 2016, these market reforms apply to mid-size employers (those with 50 to 100 employees) and states may extend the option to renew existing policies to those employers as well.
Requirements that Apply to Plans Renewed Under This Exception
See full download for corresponding data.
All newly-issued policies must meet all of the ACA requirements.
Insurers that choose to renew existing policies must send a notice to all individuals and small businesses each year that explains:
Renewed policies will satisfy the individual’s requirement to have “minimum essential” coverage. It appears that each renewed policy will need to be evaluated to determine whether it meets minimum value (60%). Access to affordable, minimum value coverage through an employer will make the individual ineligible for a premium tax credit/subsidy. Rate increases will need to be reported, and in some cases reviewed.
Download the full UBA ACA Advisor here.
Updated March 2017 by our partners at United Benefits Advisors: Stay in the know of how Health Savings Accounts (HSAs) work and how you can use them properly.
A health savings account (HSA) is a tax-exempt trust or custodial account set up with a qualified HSA trustee (such as a bank or insurance company) that is used to pay or reimburse certain medical expenses.
HSAs were first available as of January 1, 2004, and have grown greatly in popularity. An eligible individual (with or without employer involvement) can establish an HSA. Eligible participating individuals can make contributions, up to statutory limits, and get a tax deduction. Investment earnings on HSA accounts are tax free, and HSA funds used to pay qualified medical expenses are completely tax free. Employers contributing to their eligible employees’ HSAs, or that offer HSAs through a cafeteria plan also receive federal tax deductions for the contributions.
As a result of these benefits, HSAs are highly regulated; by Internal Revenue Code Section 223, as well as numerous IRS notices and guidance documents. IRS Publication 969 provides a basic overview of HSA regulations for employers and employees.
To be an eligible individual and qualify for an HSA, you must meet the following requirements:
High Deductible Health Plan
In order to participate in an HSA, an individual must be covered under an HDHP on the first day of the month. In 2016, that means the individual must have an annual deductible of at least $1,300 for self-only coverage, and the deductible and out-of-pocket expense cannot exceed $6,550. These dollar figures change annually. For an individual enrolled in family coverage (or, other than self-only), the deductible must be at least $2,600 in 2016, and the deductible and out-of-pocket expenses cannot exceed $13,100. 2 ©2017 United Benefit Advisors, LLC. All rights reserved. The HDHP must provide “significant benefits;” for example it could not exclude in-patient care or hospitalizations, be a fixed indemnity benefit, or only cover certain specified diseases such as cancer.
Other Disqualifying Coverage
Disqualifying coverage problems can be difficult for employees to understand, and care should be taken to educate them on what disqualifying coverage is.
Interplay Between Health FSAs and HSAs
Special issues can arise when an employer offers multiple benefit plans, including a traditional health plan with an FSA account, and an HDHP with an HSA account. These same issues arise when an employer looks to change the benefit plan it offers from a traditional plan with an FSA and an HDHP with an HSA.
When an individual has an FSA, they have coverage that disqualifies them from being HSA eligible. The question becomes, when are they considered to have “dropped” the FSA in order to gain HSA eligibility? The answer is different depending on the FSA’s plan design and whether the individual has a remaining balance at the end of the plan year.
Health FSA with a Grace Period
Health FSA with Carryovers
Being entitled to Medicare makes an individual ineligible for an HSA, even if the individual is enrolled in a qualifying HDHP.
Internal Revenue Code (IRC) Section 223 reads: “Medicare eligible individuals. The [contribution limit] under this subsection for any month with respect to an individual shall be zero for the first month such individual is entitled to benefits under title XVIII of the Social Security Act and for each month thereafter.”
Being eligible for and being entitled to Medicare are not the same. Individuals become entitled to Medicare through their age, through disability, or due to end stage renal disease (ESRD).
Individuals are entitled to Medicare once they are 65 years old and they either have applied for and are receiving benefits from the Social Security or Railroad Retirement Board, or, are eligible for monthly retirement benefits from Social Security or the Railroad Retirement Board (but have not applied for them) but have filed an application for Medicare Part A.
For an individual who is working and aged 65 or over to maintain HSA eligibility he or she must:
When employment-related coverage ends, the individual has eight months to enroll in Medicare Part A, which, once effective, will be effective for six months retroactively, but no earlier than the first day of eligibility.
Retroactive Medicare Coverage
Medicare Part A coverage begins the month an individual turns age 65, provided the individual files an application for Medicare Part A (or for Social Security or Railroad Retirement Board benefits) within six months of the month in which the individual turns age 65. If the individual files an application more than six months after turning age 65, Medicare Part A coverage will be retroactive for six months.
Individuals who delayed applying for Medicare and were later covered by Medicare retroactively to the month they turned 65 (or six months, if later) cannot make contributions to the HSA for the period of retroactive coverage. There are no exceptions to this rule.
However, if they contributed to an HSA during the months that were retroactively covered by Medicare and, as a result, had contributions in excess of the annual limitation, they may withdraw the excess contributions (and any net income attributable to the excess contribution) from the HSA.
They can make the withdrawal without penalty if they do so by the due date for the return (with extensions). Further, an individual generally may withdraw amounts from an HSA after reaching Medicare eligibility age without penalty. (However, the individual must include both types of withdrawals in income for federal tax purposes to the extent the amounts were previously excluded from taxable income.)
If an excess contribution is not withdrawn by the due date of the federal tax return for the taxable year, it is subject to an excise tax under the Internal Revenue Code. This tax is intended to recapture the benefits of any tax-free earning on the excess contribution.
Individuals who can be claimed as a dependent on someone else’s tax return are not HSA eligible.
Another complicated wrinkle in dependent status and HSAs involves whose expenses can be reimbursed from the HSA. HSAs can only reimburse the expenses of the employee, spouse, and tax dependents as defined by IRS Code Section 223(d)(2)(A) (even if the person is not eligible to set up his or her own HSA) if the expense was incurred after the HSA is established.
Determining Eligibility; Changes in Eligibility
An individual’s eligibility is determined on a monthly basis, on the first day of the month.
If an individual is enrolled in single HDHP coverage on the first day of September (and has no disqualifying coverage), the individual is eligible to contribute up to the full single contribution limit for the month (1/12 of the annual limit) of September, as well as October, November, and December. If an individual enrolls on the 15th of September in single HDHP coverage (and has no disqualifying coverage), the individual can begin contributing up to the full single contribution limit for the months of October, November, and December, but not the month of September. That is because the individual was not HSA eligible on the first day of September. If an individual changes from family to single coverage, or vice versa, the limit for that month is based on the individual’s coverage as of the first day of the month.
The amount you or any other person can contribute to your HSA depends on the type of HDHP coverage you have, your age, the date you become an eligible individual, and the date you cease to be an eligible individual. For 2016, if you have self-only HDHP coverage, you can contribute up to $3,350. If you have family HDHP coverage, you can contribute up to $6,750.
The “last-month” rule also provides that individuals who are eligible for an HSA on December 1 (the last month of the year), are considered eligible for the entire year. The individual is considered to have the HDHP coverage on December 1 for the entire year.
If an individual changes from family to single coverage during the year, the individual’s maximum contribution amount is calculated as (X/12 x $6,750) + (Y/12 x $3,350) = $____. The dollar figures used in the formula will change annually based on the IRS contribution limits.
X represents the number of months the individual was eligible under family coverage; Y represents the months the individual was eligible for single coverage.
Individuals who reach age 55 by the end of the taxable year have their contribution limit increased by $1,000, regardless of the tier of coverage they are enrolled in. This is called a “catch-up” contribution. A married couple, both age 55 or older, can make two catch-up contributions, but there must be a separate HSA for each spouse. Because HSAs are individual trusts, spouses cannot have a joint HSA (but each spouse can spend his or her individual HSA dollars on the spouse’s medical expenses).
The IRS has a “special rule” for married individuals that allows a couple to divide the maximum HSA contribution between spouses so long as one of them has family HDHP coverage, and neither has disqualifying coverage. The IRS provides the following example:
Beginning the first month an individual is enrolled in Medicare (or entitled to Medicare) the contribution limit is zero.
If an individual makes contributions in excess of the IRS annual limits, he or she must pay a 6 percent excise tax on the excess contributions, and the excise tax will apply to each year the excess contribution remains in the individual’s account. The excise tax is paid with IRS Form 5329.
Employers may contribute to an employee’s HSA, but their contributions count toward the individual’s total contribution limit for the year.
One of two sets of nondiscrimination rules applies to HSA contributions from employers. If the employer makes contributions through a Section 125/cafeteria plan, the contributions are included in the plan’s cafeteria plan nondiscrimination testing. These rules generally prohibit employers from favoring highly compensated or key employees.
Comparable contributions. If the employer does not include the HSA in its Section 125/cafeteria plan, it is subject to the comparable contributions rule.
In this case, if an employer makes contributions, it must make comparable contributions to all comparable participating employees’ HSAs. Contributions are comparable if they are either:
This rule prohibits employers from implementing HSA “matching” programs, or using HSA contributions as a wellness incentive.
Comparable participating employees:
Individuals may receive tax-free distributions from their HSA to pay or be reimbursed for qualified medical expenses incurred after the establishment of the HSA. If an individual loses HSA eligibility at any point, he or she can continue to spend remaining HSA dollars on qualified medical expenses.
HSA-qualified expenses are all medical expenses allowed by IRC Section 213, except insurance premiums (unless for COBRA, long-term care insurance or Medicare supplemental, which may be reimbursed). If you use HSA funds to pay premiums for COBRA, long-term care insurance, or Medicare supplement coverage, you cannot claim the health coverage tax credit for those premiums.
Qualified medical expense incurred overseas may be paid with an HSA. Care should be taken to ensure the expense is documented and meets the requirements under IRC Section 213.
Non-prescription or over-the-counter (OTC) medications other than insulin are not considered a qualified medical expense, unless you have a prescription for it. For example, if your physician wrote you a prescription for aspirin or pre-natal vitamins, you could purchase them over-the-counter with your HSA funds.
Qualified medical expenses are those incurred by the following persons.
A child of parents who are divorced (or separated, or living apart for the last six months of a calendar year) are treated as the dependents of both parents, regardless of whether the custodial parent releases the claim to the child’s exemption.
HSAs also have prohibited transactions, including the lending of money between the individual and the HSA. This means that, if an individual overdraws the HSA account (which is considered lending money), the individual loses HSA eligibility for the entire year, and will be subjected to an additional 20 percent excise tax. Federal law will require the bank operating the HSA to close it, and the individual cannot reopen the account at that bank, or any other bank, for the entire year.
HSA holders are obligated to keep sufficient records to show that any distributions from their HSA were used exclusively to pay or reimburse qualified medical expenses, that the expense was not paid previously or from another source, and that the individual did not take the expense as an itemized deduction in any year.
Thanks to our partners at United Benefits Advisors, an important opportunity has been brought to our attention that could be crucial for your business.
The U.S. Congress is currently considering health care reform proposals that would eliminate or place a cap on the employer-tax exclusion for health insurance. Eliminating the exclusion would eliminate most of the advantages of employer-sponsored insurance, while capping it would degrade the benefit and serve as a tax increase for middle-class Americans.
As an employer, you would be most directly affected by the elimination or cap of the employer tax exclusion. Did you know that more than 175 million Americans, including those covered by unions, currently receive their coverage through this system, largely due to the tax-exclusion where employers provide contributions for an employee’s health insurance which are excluded from that employee’s compensation for income and payroll tax purposes?
How Can I Learn More About This Issue?
The National Association of Health Underwriters (NAHU) has created easy-to-understand infographics about the employer-tax exclusion and the insurance risk pool that can help. You can also read details about the employer-tax exclusion.
What Can You Do?
You can take action today by sharing with your senators and representatives why the exclusion must be preserved in any health care reform legislative proposals. NAHU provides an online form so you don’t have to track down how to reach your state’s legislators.
If You Don’t Want to Send an Email
You can also reach your legislators by phone. The U.S. Capitol Switchboard can be reached at 202-224- 3121. You are welcome to use the prepared text as talking points when calling your legislators, or to expand on the prepared message to share your personal story on how this issue will impact you.
Download the UBA Notification here.
Information courtesy of our partner, United Benefits Advisors.
Entities such as employers with group health plans that provide prescription drug coverage to individuals that are eligible for Medicare Part D have two major disclosure requirements that they must meet at least annually:
Because there is often ambiguity regarding who in a covered population is Medicare eligible, it is best practice for employers to provide the notice to all plan participants.
CMS provides guidance for disclosure of creditable coverage for both individuals and employers.
Who Must Disclose?
These disclosure requirements apply regardless of whether the plan is large or small, is self-funded or fully insured, or whether the group health plan pays primary or secondary to Medicare. Entities that provide prescription drug coverage through a group health plan must provide the disclosures. Group health plans include:
Health flexible spending accounts (FSAs), Archer medical savings accounts, and health savings accounts (HSAs) do not have disclosure requirements. In contrast, the high deductible health plan (HDHP) offered in conjunction with the HSA would have disclosure requirements.
There are no exceptions for church plans or government plans.
Determining if Coverage is Creditable
The Medicare Modernization Act (MMA) provides that coverage is creditable if it provides prescription drug “coverage of the cost of the prescription drugs the actuarial value of which . . . to the individual equals or exceeds the actuarial value of standard prescription drug coverage.”
Plans can determine if they are creditable or not by meeting the plan design safe harbor or by actuarial determination. Practically speaking, many carriers for fully insured plans provide employers with creditable coverage information; however, employers are still responsible for the applicable disclosures to participants and CMS.
CMS guidance offers a design-based safe harbor for determining creditable coverage status. Specifically, a plan is deemed to be creditable if it:
An integrated plan is any plan of benefits that is offered to a Medicare eligible individual where the prescription drug benefit is combined with other coverage offered by the entity (for example, medical, dental, vision, etc.) and the plan has all of the following plan provisions:
If a plan does not meet the safe harbor based on its design, it will need to obtain an actuarial determination. Only plans that are seeking the retiree drug subsidy must provide CMS with the actual attestation documents from the actuary; however, employers should consider retaining the documents as best practice.
Disclosures to Plan Participants
The MMA penalizes individuals for late enrollment in Medicare Part D if they do not maintain “creditable coverage” for a period of 63 days or longer following their initial enrollment period for drug benefits. Therefore, individuals must be informed if the employer-provided coverage is, in fact, creditable. CMS provides model notices for creditable coverage and non-creditable coverage disclosures in both English and Spanish.
Disclosures to individuals must be made:
If the creditable coverage disclosure notice is provided to all plan participants annually, prior to October 15 of each year, CMS will consider items 1 and 2 above to be met.
Method of Delivery
Employers can provide participants with separate notices, or, under certain conditions, can provide the notice with enrollment materials or summary plan descriptions (SPDs).
If the disclosure is provided with other information (such as in the SPD), it must be “prominent and conspicuous,” which means it must be in “at least 14 point font, in a separate box, bolded, or offset on the first page” of the other information provided.
Tip: An SPD is the document provided to participants to explain their rights and obligations under the plan. It is intended to provide a summary of the plan’s terms and should be written in a way the average participant can understand it. However, it has become increasingly common for plans to use a combination plan document/SPD and most Department of Labor (DOL) offices permit this. The group insurance policy or certificate is not an SPD.
Employers may provide the notice by mail, or electronically if electronic distribution method requirements are met. Disclosures should not be handed out in person.
Recipients of electronic disclosures are divided into two groups – those with work-related computer usage, and those who do not use computers as part of their jobs. An employee is considered to have work-related computer usage if:
An employee who uses a computer as part of his or her job does not need to consent to receive disclosures electronically.
Individuals who do not access a computer as part of their work for the employer must specifically consent to receive disclosures electronically. This would include retirees, as well as active employees in many types of jobs. The written consent requirements are fairly complicated. Prior to providing consent, an individual must be given a clear statement that explains:
The individual must provide an email address for delivery of the documents. The individual must provide consent in a manner that demonstrates his or her ability to access the information in the electronic format that will be used, so many employers require that the consent be provided electronically. An employer may not simply provide a kiosk for employees who do not use computers as part of their jobs. Likewise, it may not provide thumb drives of documents to employees who do not use computers as part of their jobs unless it obtains the employee’s consent.
Delivery to Spouses and Dependents
If an employee and an employee’s spouse or dependents are covered under the same plan, a single notice is sufficient for the eligible individual and the individual’s family. However, if an employer knows that a spouse or dependent is Part D eligible and has a different address, the employer is obligated to send a separate notice to the spouse or dependent.
Disclosures to CMS
Employers must provide CMS with a “Disclosure to CMS Form” that is completed and sent electronically through the CMS website. The form must be provided annually and:
CMS provides an instruction guide with screen shots for completing the form online. Employers should gather the information necessary to complete the form prior to beginning to complete the form, as some of the questions may require preparation on the part of the employer. For example, employers must estimate how many Part D eligible individuals they expect to be covered as of the first day of the plan year.
Download the UBA Compliance Advisor here.
Our February Dish is brought to you by our very own Susan Henderson!
As our VP of Operations and HR, Susan comes packed with years of valuable experience. Her knowledge, motivation, and professional personality are only a phone call away!
When it comes to eating out, Susan is a fan of two spots in the Oshkosh area: Gardina’s Wine Bar and Café and one of its additions, The Ruby Owl Tap Room. At the Ruby Owl, she claims their Veggie Burger is the “best ever,” and their Balsamic Glazed Meatloaf Sandwich is definitely a dish to try!
For home cooking, Susan is sharing a crock pot version of a family favorite! Chicken and dumplings is a classic meal that really can’t be beat! Unless Grandma makes it from scratch, of course.
Slow Cooker Chicken and Dumplings
Here’s what you need:
It may not be Grandma’s recipe, but it’s a delicious substitute if you can’t get over there for dinner! Thanks Susan!
February 14, 2017
The Bureau of Labor Statistics (BLS) recently released statistics on work-related injuries and illnesses in 2014. According to the BLS, two key factors are used to measure the severity of these injuries and illnesses:
* Incidence rate: The number of cases, per 10,000 full-time employees, of injuries and illnesses that require time away from work.
* Average days away from work: The average number of days an employee spends away from work to recover from an injury or illness. The BLS found that the overall incidence rate of nonfatal occupational injury and illness cases in 2014 was 107.1, down from a rate of 109.4 in 2013. The number of days away from work was approximately the same in both years. Additionally, the BLS detailed the most common workplace injuries and illnesses, as well as the most commonly affected parts of the body.
Common Injuries and Illnesses
Sprains, strains and tears were the most common workplace injury in 2014. The incidence rate for these injuries was approximately 38.9 cases per 10,000 full-time employees, which represents a decrease from 2013’s rate of 40.2 cases. However, these are still significant injuries; on average, workers with sprains, strains or tears needed 10 days away from work to recover.
The statistics also show that soreness and pain were common injuries, but generally required fewer days away from work.
Commonly Affected Parts of the Body
The upper extremities (e.g., hands, shoulders) were most affected by injuries and illnesses in 2014, with an incidence rate of 32. Hands accounted for 40 percent of those cases, the most among upper extremities. However, shoulder injuries and illnesses required an average of 26 days away from work to recover, more than any other part of the body.
The BLS specifically noted that musculoskeletal disorders (MSDs) accounted for 32 percent of all workplace-related injuries and illnesses in 2014. Although the incident rate of MSDs was lower than it had been in 2013, these injuries can affect employees in any industry.
For more information on preventing workplace injuries and illnesses, contact Hierl Insurance Inc. today.
OSHA requires employers to keep and maintain records of work-related injuries and illnesses. However, if an employee develops an injury or illness while performing a personal task or is injured outside of his or her normal work hours, it can be difficult to determine your OSHA obligations. That’s why OSHA recently clarified the requirements necessary for an injury or illness to be exempt from recordkeeping requirements.
In the clarification, OSHA presented an example in which an employee brought a plow to work, which he intended to loan to a co-worker. After the employee’s regular shift ended, he attempted to move the plow to the co-worker’s truck. However, in the process, the employee injured his back.
OSHA stated that the injury presented in this example would not be considered work-related, and would therefore be exempt from recordkeeping regulations. This is because the injury met both of the requirements needed to fall under the personal-task exemption:
* The injury or illness must solely be the result of an employee performing a personal task at the workplace
* The injury or illness must occur outside of an employee’s assigned work hours, including during formal and informal break times.
The Federal Motor Carrier Safety Administration (FMCSA) recently released a final rule that will create a national drug and alcohol testing clearinghouse for commercial driver license (CDL) holders who operate commercial motor vehicles (CMVs). Under the rule, drivers will be added to the clearinghouse if they test positive for drugs or refuse to perform a test required by the Department of Transportation (DOT). Then, employers will be able to review the testing history of applicants, drivers who work for more than one motor carrier and long-term employees.
Once the clearinghouse has been created, employers will be required to do the following:
* Search the clearinghouse at least once every year for current drivers.
* Review the system for any information on driver applicants.
The agency has stated that the rule will assist employers in determining whether a driver needs to begin or continue a return-to-service process before driving a CMV. And, although the final rule became effective on Jan. 4, 2017, compliance will not be required until Jan. 6, 2020.