Association Health Plans Meet the 2018 Form M-1

The 2018 version of the Form M-1 can be used to register for a new plan and to file the annual report for an in-force plan. Continue reading this blog post for more information about the new Form M-1.


The Employee Benefits Security Administration (EBSA) is continuing to do what it can to help bring the new class of association health plans (AHPs) to life.

EBSA, an arm of the U.S. Department of Labor, unveiled the 2018 version of the Form M-1 Monday.

Administrators of multiple employer welfare arrangements (MEWAs) that provide medical benefits use Form M-1 to report on the MEWAs’ operations to the DOL.

The administration of President Donald Trump completed work on major new AHP regulations in June. The administration is hoping small employers will use the new AHPs to shield themselves from some state and federal mandates and to get a chance to benefit from being part of a large coverage buyer.

Any AHPs out there, including any AHPs formed under the new regulations, will need to file the 2018 Form M-1 with the Labor Department, EBSA said Monday.

An AHP, or other MEWA, can use Form M-1 both to register a new plan and to file the annual report for an in-force plan.

The 2018 annual report for an AHP or other MEWA in operation now will be due March 1, 2019.

If agents, brokers, benefit plan administrators or other financial professionals are trying to start AHPs, they are supposed to use Form M-1 to register the AHPs at least 30 days before engaging in any AHP activity.

“Such activities include, but are not limited to, marketing, soliciting, providing, or offering to provide medical care benefits to employers or employees who may participate in the AHP,” EBSA officials said in the form release announcement.

Resources

Links to AHP information, including information about the 2018 Form M-1, are available here.

SOURCE: Bell, A. (4 December 2018) "Association Health Plans Meet the 2018 Form M-1" (Web Blog Post). Retrieved from https://www.thinkadvisor.com/2018/12/04/association-health-plans-meet-the-2018-form-m-1/


Happier Holidays, the HR Way

A significant percentage of respondents in a new survey featured in HR Dive reported feeling the greatest sense of belonging in their workplace. Continue reading this blog post to learn more.


Most people, according to a new survey featured in HR Dive, have the greatest sense of belonging in their own homes. That may not be surprising news, but what is interesting is that one-third of respondents felt the greatest sense of belonging in their workplace. A significant percentage, 40 percent, attribute that feeling to actions their colleagues and managers take to check in on them, both personally and professionally. Belonging improves employee retention and productivity, certainly, but it requires acknowledgment of diversity and efforts at inclusion.

This critical sense of belonging can be deepened, or hampered, during the holiday season. Beyond secular or national holidays like Thanksgiving and New Year's, the fall and winter months are full of faith-based holidays beyond Christmas. The Society for Human Resource Management has some tips as well as a list of celebrations for the coming months intended to help companies create inclusive workspaces for people of more faiths and cultures. When employees feel valued and known, they are more engaged.

Mutual respect is not only good for morale, but it’s also good for productivity. Some tips include sharing more about holidays in internal communications, creating luncheons that feature traditional dishes or are mindful of dietary restrictions or fasting practices, or sponsoring a service or volunteer day.

Read more:
One-third of workers report feeling a sense of 'belonging' in the workplace
Ask an HR Expert: How Can We Foster Inclusivity Among Our Multifaith Workforce This Holiday Season?

SOURCE: Olson, B. (27 November 2018) "Happier Holidays, the HR Way" (Web Blog Post). Retrieved from http://blog.ubabenefits.com/happier-holidays-the-hr-way


The benefits issue that costs employers big: Ineligible dependents on company plans

Are you paying insurance premiums for dependents who are ineligible for your company health plan? Almost 10 percent of enrolled dependents are ineligible for the programs they are enrolled in. Read on to learn more.


Are you paying insurance premiums for people who aren’t qualified to be on your company plan?

For some employers, too often the answer is “yes.”

In our experience, we find that nearly 10% of dependents enrolled in employee health and welfare plans are not eligible to be in the program. And for a company with a couple of hundred employees that spends around $2 million a year on benefits, ineligible dependents can become a significant financial issue.

When employers pay for ineligible dependents, costs increase for them and employees. Unfortunately, it’s an all-too-common issue that employers need a solid strategy to combat.

So how do ineligible dependents get enrolled in the first place? There are a couple of common ways that employers end up paying health insurance premiums for ineligible dependents. The most basic factor is a change in a person’s situation — children pass the age of 26, spouses get jobs, people get divorced, etc. — and the employee is unaware of the need to notify the plan sponsor. Most often, these situations arise because the employer doesn’t have a process in place.

But some situations are more nefarious: An employee mischaracterizes someone as a dependent. They may claim that a nephew is a son, or that they’re still married to an ex-spouse. In either of these situations, the employer loses.

Prevent ineligible dependents with best practices

Prevent paying for ineligible dependents by putting into place best practices that begin when a new employee joins the company.

During onboarding, investigate each potential plan member when the employee applies for insurance coverage. That means seeking documentation — such as marriage certificates and birth certificates — to verify that a person is, in fact, married, or that their kids are their kids and not someone else’s. Following these processes at the outset prevents the awkwardness of having to question employees about their various family relationships. Nobody wants to ask a colleague if the divorce is final yet.

To make it easy for employees to verify everyone’s eligibility, provide access to a portal where they can upload scans or images of relevant documents. This will also make it easier to track—and keep track of—onboarding documents and dependent audits when the time comes.

Once this best practice is established, it’s important to conduct periodic dependent eligibility audits, as required by ERISA. The employer can conduct an audit or hire an external auditor. This decision is usually driven by the size of the workforce.

The most logical time to conduct an audit is during benefit enrollment. Employees are already considering options for the next plan year, and they likely won’t be confused by the need to submit verifying documents. (During this exercise, it’s also a good idea to ask plan participants to verify beneficiaries on employer-provided life insurance.)

Some employers — again, depending on the size of the workforce — will conduct random sample audits of 20-25% of their employee population. Obviously, the larger the sample size, the better. Benefits administration platforms typically streamline this process.

What happens when employers identify an ineligible dependent?

Many employers offer workers an amnesty period during which an employee can come forward to say they have someone that should be taken off the plan. If the plan sponsor identifies an ineligible dependent, employees are typically offered a one-time pass. Then, they must sign an affidavit attesting that they can be terminated if it happens again.

If the employer has processed insurance claims for an ineligible dependent, they can declare fraud and seek back payment of claims payouts. Again, most in this situation prefer a more benevolent approach and will ask the employee to make monthly differential payments until the account is even. Conducting regular dependent eligibility audits as part of the benefits administration process needs to be handled with finesse for the good of organizational culture.

Some employers may shy away from conducting audits out of concern for creating awkward situations. But frankly, it’s the plan sponsor’s job to help them navigate the waters, educate them and keep them engaged in the process by becoming their best advocates. This will not only help enhance the efficiency and accuracy of employee benefit offerings, but it will result in a smoother ride for everyone involved.

Ensuring that a health and welfare benefits program follows eligibility best practices is the responsibility of the plan sponsor. But employees have a share in that responsibility, too.

SOURCE: O'Connor, P.(28 November 2018) "The benefits issue that costs employers big: Ineligible dependents on company plans" (Web Blog Post). Retrieved from:


Facebook Unveils New Career-Development Portal

Social networking company, Facebook, recently revealed that they are launching a career-development portal that provides accessible, relevant content to entry-level job seekers. Read on to learn more.


Facebook is jumping into the learning market in a big way, announcing the launch of Learn with Facebook at its New York offices yesterday, a big step toward the social-networking giant’s recently stated goal of equipping 1 million business owners in the U.S. with digital skills by 2020.

Learn with Facebook is a career-development portal that offers introductory, free-of-charge courses in both hard and soft skills. It’s aimed at people hoping to re-enter the workforce after a period of absence as well as those wishing to acquire skills that will help them compete for entry-level jobs in the digital economy, says Fatima Saliu, Facebook’s head of policy marketing.

“We’re facing a major skills gap in this country, and Learn with Facebook is our attempt to address that,” she says. Learn with Facebook has already been launched in France and Germany, says Saliu, and will expand to other markets as well.

Learn with Facebook is a direct move into LinkedIn’s territory, although Facebook representatives denied yesterday that it was seeking to compete directly with the business-focused social network. LinkedIn has steadily built up its own learning offerings since it acquired Lynda.com in 2015 and rebranded it as LinkedIn Learning. Last week, Harvard Business Publishing announced a new partnership with LinkedIn that will allow customers of HBP to access its content directly via LinkedIn Learning’s platform.

The courses currently available on Learn with Facebook include tutorials on digital marketing as well as resume writing and job interviewing. Facebook is working with the Goodwill Community Foundation to develop course material and adapt it to the needs of local communities, says Saliu. “Our goal is to provide accessible, relevant content to entry-level jobseekers,” she says.

Facebook is also enhancing its Jobs on Facebook services by allowing businesses to share their job postings on Facebook groups as well as on their own pages and newsfeeds. The company says more than 1 million people have found jobs via Facebook since it launched the service last year.

Facebook is also making updates to its Mentorship tool, which is designed to make it easier for members of Facebook groups to connect with others who have specific experience or expertise. Users will now be able to sign up to share information on what they’re offering or looking for, making it easier for other Group members to find and connect with them on their own rather than going through a Group administrator first, says Michelle Mederos, Facebook Mentorship product designer.

Facebook Groups have enabled people working in high-stress, low-prestige occupations such as certified nursing assistant obtain mentoring and support, says Seth Movsovitz, founder of a Facebook Group called CNAs Only.

Although LinkedIn currently remains the dominant social-media player in the jobs space, it’s clear that Facebook is determined to be a big player as well. For employers that are desperate to fill jobs in a tight labor market, more competition between the two can only be a good thing.

SOURCE: McIlvaine, A. (15 November 2018) "Facebook Unveils New Career-Development Portal" (Web Blog Post). Retrieved from http://hrexecutive.com/facebook-unveils-new-career-development-portal/


3 trends and 4 survival tips for managing millennials in 2019

Millennials are America's most diverse generation and will be the prime engine of the workplace for years to come. Read this blog post for survival tips for managing millennials.


If anyone knows more about millennials than an actual millennial, it’s Brian Weed, CEO of Avenica. Founded in 1998, Avenica’s personnel services are focused exclusively on recent college graduates and the companies who are looking for such talent.

“Our goal is to place recent college graduates on the right career-track, finding entry-level positions for them at companies offering strong professional growth,” Weed says.

Millennials have been given “kind of a bad rap” by being overly stereotyped and studied. “Millennials are America’s most diverse generation. They hold more college degrees than any other generation, and they’ve experienced economic and political turmoil. They’re savvy, educated, skeptical, and on top of it all, they’re idealists. All of this has led to vast changes in the ways today’s workforce views business, engages with their organizations and leaders and makes decisions about their careers,” he says. And yet, just as with any generation, one must be cautious about assuming one profile fits all.

However one feels about this generation, there’s the fact that millennials are going to be the prime engine of the workplace for years to come. “The truth is that companies have to adapt to them, not the other way around,” he says.

Given the company’s focus and its tenure of service, BenefitsPRO asked Weed to identify three top millennial worker trends for 2019. Here’s his list:

1. Shifting motivations

Salary and culture continue to rank high on the list for attracting millennial and Gen Z candidates, but the following factors are increasingly important:

Flexibility: They expect more control over where and when they can work, with the ability (enough PTO and work-life balance) to travel and have other life experiences.

Mission driven: They are more in touch with the environment, society, and the future of both. They feel they are not only representative of their organization, but their organization also represent who they are as individuals and want to be a part of organizations that share similar views. They look for leaders who will make decisions that will better the world, not just their organizations, and solve the problems of the world through their work.

Development and training opportunities: Because millennials have seen such dramatic shifts in the economy, they seek to have more control over the future of their careers. Not only to “recession proof” but also to “future proof” their careers by constantly learning and developing.

2. Declining levels of loyalty and increased job hopping

These phenomena, well-known to employers or millennials, are largely due to:

Shifting motivations (outlined above): The key to managing this group is understanding the shifting motivations and finding ways to meet those needs/wants will help organizations attract and retain top talent.

Higher value placed on experiences, constantly wanting to try and learn new things: Managers need to give these employees opportunities to grow and develop in their roles is essential, but also opportunities to explore different fields and disciplines is also key. Keeping the work and the environment interesting and diverse will keep millennial employees engaged for longer.

Less patience, with a desire for frequent indicators of career progress (higher pay and/or promotions): Job hopping often allows the quickest opportunity to make more money and climb the career ladder. As a result, organizations are building in a quicker cadence for promotions and pay raises.

3. An increasing lack of basic professional skills/awareness

Many of these talented young people lack essential knowledge about what to wear, how to act and how to/engage in an office setting. Here’s how to respond:

Managers need to be ready to guide these new workforce entries into the professional skills areas. They often don’t have a network of older (parents/relatives) professionals around them to set an example and advise on what “professionalism” looks like and means. And colleges often don’t provide education in professionalism in an office setting: aside from business schools, many colleges don’t prepare students—especially those in the liberal arts—on meeting etiquette, business apps and technology, and other everyday professional practices.

Corporate onboarding of new entry-level employees often excludes the “basics” (meeting protocols, MS Office skills, etc.). While companies typically have some type of job-specific training programs, they often assume these basic office skills are there and aren’t able to see a candidate’s potential when lack of professional skills/awareness is present. This can create a barrier for highly qualified but more “green” candidates, especially first-generation graduates. Effective companies will develop training, coaching, and mentorship programs can help once on the job.

Weed’s 4 survival tips to managers of millennials

1. Create clear and fast-moving career tracks.

  • Create distinct career tracks with clear direction on how to advance to each level.
  • Restructure promotion and incentive programs that give smaller, more incremental promotions and salary raises, giving more consistent positive reinforcement and closer goals that make it more enticing to stay.
  • Create professional development opportunities that help them advance in those career tracks and build other skills they need and want.
  • Create ways young employees can explore other career tracks without leaving the company. Millennials and Gen Z’s have a higher propensity for changing their minds and/or wanting different experiences, so consider ways that enable employees to make lateral moves, or create rotational programs that allow inexperienced professionals to get experience in a variety of business capacities and are then more prepared to choose a track.

2. Alongside competitive compensation packages that include 401k matching programs and comprehensive insurance offerings, provide benefits that allow them to have a sense of flexibility when it comes to how they work.

  • Working remotely, flex schedules/hours
  • Floating holidays–especially beneficial as the workforce becomes more and more diverse
  • Restructure PTO that gives employees more autonomy and responsibility for their work
  • Tuition reimbursement programs to increase retention and build leaders internally

3. Create a strong company culture: company culture is one of the strongest recruiting and retention tools. Go beyond the flashy tactics of having an on-site game room and fun company outings and bring more focus to the company’s mission. Create and live/work by a set of core values that represents your company’s mission. People will be more engaged and move beyond just being their role or position when they feel connected to the mission.

4. Challenge without overworking. Boredom and stress are equally common as factors for driving millennials out of a workplace. Allow involvement in bigger, higher-level projects and discussions to provide meaningful learning opportunities, and create goals that stretch their capabilities but are attainable.

SOURCE: Cook, D. "3 trends and 4 survival tips for managing millennials in 2019" (Web Blog Post). Retrieved from https://www.benefitspro.com/2018/11/13/3-trends-and-4-survival-tips-for-managing-millenni/


2019: A Look Forward

A number of significant changes to group health plans have been made since the Affordable Care Act (ACA) was enacted in 2010. Many of these changes became effective in 2014 and 2015 but certain changes to a few ACA requirements take effect in 2019.

 Changes for 2019 

  1. Cost-sharing Limits – Non-grandfathered plans are subject to limitations on cost sharing for essential health benefits (EHB). The annual limits on cost sharing for EHB are $7,900 for self-only coverage and $15,800 for family coverage, effective January 1, 2019.
    • Health plans with more than one service provider can divide maximums between EBH as long as the combined amount does not exceed the out-of-pocket maximum limit for the year.
    • Beginning in 2016, each individual – regardless of the coverage the individual is enrolled – is subject to the self-only annual limit on cost sharing.
    • The ACA’s annual cost-sharing limits are higher than high deductible health plans (HDHPs) out-of-pocket maximums. For plans to qualify as an HDHP, the plan must comply with HDHP’s lower out-of-pocket maximums. The HDHP out-of-pocket maximum for 2019 is $6,750 for self-only coverage and $13,500 for family coverage.
  2. Coverage Affordability Percentages – If an employee’s required contribution does not exceed 9.5 percent of their household income for the taxable year (adjusted each year), then the coverage is considered affordable. The adjusted percentage for 2019 is 9.86 percent.
  3. Reporting of Coverage – Returns for health plan coverage offered or provided in 2018 are due in early 2019. For 2018, returns must be filed by February 28, 2019, or April 1, 2019 (if electronically filed). Individual statements must be provided by January 31, 2019.
    • ALEs are required to report information to the IRS and their eligible employees regarding their employer-sponsored health coverage. This requirement is found in Section 6056. Reporting entities will generally file Forms 1094-B and 1095-B under this section.
    • Every health insurance issuer, self-insured health plan sponsor, government agency that provides government-sponsored health insurance, and any other entity that provides MEC is required to finalize an annual return with the IRS, reporting information for each individual who is enrolled. This requirement is found in Section 6055. Reporting entities will generally file Forms 1094-C and 1095-C under this section.
    • ALEs that provide self-funded plans must comply with both reporting requirements. Reporting entities will file using a combined reporting method on Forms 1094-C and 1095-C.
    • Forms Used for Reporting – Reporting entities must file the following with the IRS:
      1. A separate statement for each individual enrolled
      2. A transmittal form for all returns filed for a given calendar year.
    • Electronic Reporting – Any reporting entity that is required to file 250 or more returns in either section must file electronically on the ACA Information Returns (AIR) Program. Reporting entities that file less than 250 returns can file in paper form or electronically on the ACA Information Returns (AIR) Program.
    • Penalties – Entities that fail to comply with the reporting requirements are subject to general reporting penalties for failure to file correct information returns and failure to furnish correct payee statements. Penalty amounts for failure to comply with the reporting requirements in 2019 are listed below:
Penalty Type Per Violation Annual Maximum Annual Maximum for Employers with up to $5 million in Gross Receipts
General $270 $3,275,500 $1,091,500
Corrected within 30 days $50 $545,500 $191,000
Corrected after 30 days but before August 1 $100 $1,637,500 $545,500
Intentional Disregard $540* None N/A

**Intentional disregard penalties are equal to the greater of either the listed penalty amount or 10 percent of the aggregate amount of the items required to be reported correctly. 

Expected Changes

  1. Health FSA Contributions – Effective January 1, 2018, health FSA salary contributions were limited to $2,650. The IRS usually announces limit adjustments at the end of each year. This limit does not apply to employer contributions or limit contributions under other employer-provided coverage.
  2. Employer Shared Responsibility Regulations – The dollar amount for calculating Employer Shared Responsibility 2 penalties is adjusted for each calendar year. Applicable large employers (ALEs) must offer affordable, minimum value (MV) healthcare coverage to full-time employees and dependent children or pay a penalty. If one or more full-time employees of an ALE receive a subsidy for purchasing healthcare coverage through an Exchange, the ALE is subject to penalties.
    • Applicable Large Employer Status – ALEs are employers who employ 50 or more full-time employees on business days during the prior calendar year.
    • Offering Coverage to Full-time Employees – ALEs must determine which employees are full-time. A full-time employee is defined as an employee who worked, on average, at least 30 hours per week or 130 hours in a calendar month. There are two methods for determining full-time employee status:
      1. Monthly Measurement Method – Full-time employees are identified based on a month-to-month analysis of the hours they worked.
      2. Look-Back Measurement Method – This method is based on whether employees are ongoing or new, and whether they work full time or variable, seasonal or part-time. This method involves three different periods:
        • Measurement period – for county hours of service
        • Administration period – for enrollment and disenrollment of eligible and ineligible employees
        • Stability period – when coverage is provided based on an employee’s average hours worked.
      3. Applicable Penalties – ALEs are liable for penalties if one or more full-time employees receive subsidies for purchasing healthcare coverage through an Exchange. One of two penalties may apply depending on the circumstances:
        • 4980H(a) penalty – Penalty for not offering coverage to all full-time employees and their dependents. This penalty does not apply if the ALE intends to cover all eligible employees. ALEs must offer at least 95 percent of their eligible employees’ health care coverage. Monthly penalties are determined by this equation:
          1. ALE’s number of full-time employees (minus 30) X 1/12 of $2,000 (as adjusted), for any applicable month
          2. The $2,000amount is adjusted for the calendar year after 2014:
          3. $2,080 – 2015; $2,160 – 2016; $2,260 – 2017; $2,320 – 2018
        • 4980H(b) penalty – penalty for offering coverage – ALEs are subject to penalties even if they offer coverage to eligible employees if one or more full-time employees obtain subsidies through an Exchange because:
          1. The ALE didn’t offer all eligible employees coverage
          2. The coverage offered is unaffordable or does not provide minimum value.
          3. Monthly penalties are determined by this equation: 1/12 of $3,000 (as adjusted) for any applicable month
            1. $3,120 – 2015; $3,240 – 2016; $3,390 – 2017; $3,480 – 2018

Contact one of our expert advisors for assistance or if you have any questions about compliance in the New Year.

SOURCES: www.dol.gov, www. HHS.gov, https://www.federalregister.gov/documents/2018/04/17/2018-07355/patient-protectionand-affordable-care-act-hhs-notice-of-benefit-and-payment-parameters-for-2019, https://www.irs.gov/e-fileproviders/air/affordable-care-act-information-return-air-program


HRL - White - House

DOL reverses course on ‘80/20’ limitations for tipped employees

The Department of Labor (DOL) recently released four new opinion letters, providing insight into their views on compliance with federal labor laws. Continue reading this blog post to learn more.


Last week, the DOL issued four new opinion letters providing both employers and employees further insight into the agency’s views regarding compliance with federal labor laws.

While the letters touch on a variety of issues, perhaps the most notable change involves the DOL’s about-face regarding the amount of “non-tipped” work an employee can perform while still receiving a lower “tip-credit” wage.

Essentially, this new guidance does away with the previous “80/20” rule regarding tipped employees. Under the 80/20 rule, businesses were barred from paying employees traditionally engaged in tip-based work, like servers and bartenders, a lower minimum wage and taking a tip credit for the other portion of the employee’s wage up to applicable state and federal minimum wage requirements when those employees’ side work, like napkin folding or making coffee, accounted for more than 20% of the employee’s time.

In recent years, there has been an explosion of litigation across the country over the 80/20 rule, questioning whether the tipped employee’s “side work” amounted to more than 20% of the employee’s duties and time. Likewise, in many of those same suits, plaintiffs would challenge individual tasks associated with their side work, attempting to claim that those tasks were not so closely related to their tipped duties, but rather rose to the level of a completely different or “dual job,” meaning that the employer should not be permitted to take the tip credit for hours worked performing those tasks.

What followed was case after case of lawyers, courts and employers quibbling over minutes spent folding napkins, wiping counters, slicing lemons, and painstakingly calculating and arguing as to whether those tasks added up to 20% and whether those tasks were not closely related enough to be included in the 20% calculation.

In these kinds of cases, we’d see arguments over circumstances like the server that moonlights as a “maintenance man” versus the server that changed the lightbulb or helped sweep underneath the tables.

The ultimate result: confusion, chaos and, frankly, a treasure trove for plaintiff’s attorneys who had another arrow in their quiver in which to seek additional purported wages for clients from employers that would find it difficult, if not impossible, to account for all minutes and tasks employees were performing in busy restaurants.

Following the DOL’s opinion letter, the landscape will change. Recognizing that the existing guidance and case law had created “some confusion,” the DOL expressly stated that they “do not intend to place a limitation on the amount of duties related to a tip-producing occupation that may be performed, so long as they are performed contemporaneously with direct customer-service duties...”

However, in attempting to provide additional clarity, the DOL may have instead opened up the proverbial Pandora ’s Box of uncertainty. In identifying the list of duties that the DOL would consider “core or supplemental,” the DOL refers to the Tasks section of the Details report in the Occupational Information Network (O*NET). It goes without saying that no document can provide an exhaustive list of tasks in today’s changing marketplace. While the DOL attempted to recognize the changing nature of today’s environment in a savings-type footnote, one does not have to look too far ahead to foreshadow the response from the plaintiff’s bar arguing over the related duties listed on O*NET.

While the DOL’s new position on the 80/20 rule will certainly come as a relief to many employers with tipped employees, employers should still be mindful in evaluating tipped employees’ job duties on a regular basis. Employees that are engaged in “dual jobs” are entitled to the full minimum wage, without the tip credit.

SOURCE: Kennedy, C. (15 November 2018) "DOL reverses course on ‘80/20’ limitations for tipped employees" (Web Blog Post). Retrieved from https://www.benefitnews.com/opinion/dol-reverses-course-on-80-20-limitations-for-tipped-employees?brief=00000152-14a5-d1cc-a5fa-7cff48fe0001

This article originally appeared on the Foley & Lardner website. The information in this legal alert is for educational purposes only and should not be taken as specific legal advice.