The Vita Blog COVID-19

President Biden again formally extended the COVID-19 National Emergency (which was previously set to expire on March 1, 2022). Each National Emergency declaration generally lasts for one year unless the President announces an earlier termination or an extension (for up to another year). President Trump first declared the National Emergency on March 1, 2020. On Feb. 24, 2021, President Biden extended the National Emergency. Most recently, it was unclear whether President Biden would extend it again because, although many stakeholders requested another extension, the Biden administration is also facing some political pressure to move the country onto an "off-ramp" from the COVID-19 pandemic. Nonetheless, a formal extension was made. However, it is possible that President Biden could take action to end the National Emergency in the coming months (assuming COVID-19 cases, hospitalizations, and deaths continue to decline).
 

Employee Benefits Deadlines Will Be Further Tolled

As a result, the “tolling” of health, welfare, and retirement plan deadlines will also remain in effect. This means plan sponsors and administrators should continue to apply the deadline extensions to affected individuals on a participant-by-participant basis for the foreseeable future. This further extension means that the deadlines summarized below must continue to be tolled for one year or for 60 days from the end of the National Emergency (if President Biden declares an earlier end to the National Emergency).
 

The First Year of the National Emergency

Shortly after the COVID-19 pandemic began, joint guidance from the Department of Labor and the Department of the Treasury suspended, or “tolled,” certain deadlines for benefit plans and participants for the period beginning on March 1, 2020 and ending 60 days after the announced end of the National Emergency. This extension period is referred to as the “Outbreak Period.” The following deadlines were extended by the length of the Outbreak Period.

For Participants:

• HIPAA Special Enrollment. The 30-day deadline (or 60-day deadline, in some instances) to request enrollment in a group health plan following the loss of other group health plan coverage, the acquisition of a new dependent through marriage, birth, adoption or placement for adoption or the eligibility for premium assistance through state premium assistance subsidy, Medicaid, or CHIP.
• COBRA Notifications (by Employee to Employer). The 60-day deadline by which individuals must notify the plan of certain COBRA-qualifying events (such as a divorce or a child losing eligibility as a dependent under the plan), or a Social Security Administration determination of disability.
• COBRA Elections. The 60-day deadline for electing COBRA coverage.
• COBRA Premium Payments. The 45-day (initial) and 30-day (subsequent monthly) COBRA premium payment deadlines.
• Benefit Claims and Appeals. The plan deadlines by which participants may file a claim for benefits (under the terms of the plan) and the deadline for appealing an adverse benefit determination. This includes extensions of claims filing deadlines for Health FSAs.
• External Review. The 4-month deadline by which a claimant must request an external review of a final determination on appeal.

For Employers/Plan Sponsors:

• COBRA Notifications (by Employer to QB). The 14-day deadline to provide a COBRA election notice to qualified beneficiaries or the 44-day (14+30 days) deadline for employers who are plan administrators.

 

The Second Year of the National Emergency

Because the COVID-19 pandemic had not yet ended at the time the regulatory guidance was set to expire, the DOL issued additional guidance in February 2021, providing that the deadlines would continue to be tolled, or remain disregarded, through the earlier of:

• One year from the date the individual was first entitled to the extension relief (i.e., a date on or after March 1, 2020).
• 60 days after the end of the National Emergency (i.e., the end of the Outbreak Period).

Importantly, the second year ushered in the position that the tolling period applies on a person-by-person basis. It can be challenging to track these deadlines when the tolling period applies, so plan administrators need to take care that they are calculating the deadlines correctly.
 

The Third Year of the National Emergency

While this latest extension of the National Emergency does not change the previous guidance, it does further extend the timeline of the tolling period; participants will continue to have more time to act on these deadlines than they normally would under the applicable plan terms. Note that the individualized tolling periods continue into the third year. Also, because the National Emergency’s end remains open at this time, exactly how long participants have under these deadlines remains a moving target until the National Emergency ends.
 

Different from the Public Health Emergency

Importantly, this National Emergency declaration is different from the Public Health Emergency declaration made by the Secretary of HHS, which is tied to the COVID-19 testing requirements in the Families First Coronavirus Response Act and the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

The Public Health Emergency is set to expire on April 16, 2022. However, the Secretary may extend it for subsequent 90-day periods for as long as the public health emergency continues to exist or may terminate the declaration whenever it is determined that the public health emergency has ceased to exist.

On Wednesday, February 9th, Governor Gavin Newsom signed Senate Bill 114, providing additional COVID-19 supplemental paid sick leave for covered employees unable to work or telework due to certain reasons related to COVID-19.
 

Who is subject?

Employers with 26 or more employees are subject to this new legislation. Small employers with 25 or fewer workers are exempt.
 

When will it take effect?

The law will take effect on February 19th, 2022, ten days after the bill was signed. It will be retroactive to January 1st, 2022, and will remain in effect through September 30th, 2022.
 

Who is eligible?

Covered employees include those working full-time, or those that are scheduled to work an average of 40 hours per week in the 2 weeks preceding the date the covered employee took COVID-19 supplemental paid sick leave.

Employees who do not work 40 hours per week are entitled to COVID-19 supplemental paid sick leave equal to the total number of hours the employee is normally scheduled to work over one week. Employees who work variable hours are entitled to seven times the average number of hours worked per day over a six-month lookback period preceding the date the covered employee took COVID-19 supplemental paid sick leave.
 

What is the duration of, and the qualifying reasons for, the additional leave?

Covered employees are now entitled to two separate 40 hour allotments of supplemental paid sick leave.

A covered employee may take up to 40 hours of COVID-19 paid sick leave if they are unable to work or telework due to one or more of the following reasons:
 

• The covered employee is subject to a quarantine or isolation period related to COVID-19 as defined by federal, state or local orders
• The covered employee is advised by a healthcare provider to self-quarantine or isolate due to COVID-19 related concerns
• The covered employee is attending an appointment for themselves or a family member to receive a COVID-19 vaccine or vaccine booster (employers may limit the supplemental paid sick leave to 3 days (or 24 hours) unless the covered employee provides verification from a healthcare provider that the employee or family member is continuing to experience symptoms related to the vaccine or vaccine booster)
• The covered employee is experiencing symptoms, or caring for a family member experiencing symptoms, related to a COVID-19 vaccine or vaccine booster
• The covered employee is experiencing symptoms of COVID-19 and is seeking a medical diagnosis
• The covered employee is caring for a child whose school or place of care is closed or otherwise unavailable due to COVID-19

A covered employee may take up to an additional 40 hours of COVID-19 paid sick leave if they or a family member tests positive for COVID-19.

Employers are authorized to require the covered employee to take another test on the fifth day after the first positive test and provide documentation of the results. Employers are also authorized to require the covered employee to provide documentation of a family member’s positive test result before paying the COVID-19 paid sick leave. If the covered employee refuses to provide documentation as requested, the employer is not obligated to provide the additional COVID-19 paid sick leave. Employers are required to make a test available at no cost to the covered employee.
 

What is the rate of pay?

A covered employee is to be compensated for each hour of COVID-19 paid sick leave at their regular rate of pay, not to exceed $511 per day, or $5,110 in aggregate. An employer cannot require a covered employee to use any other paid or unpaid leave, time off, or vacation time prior to or in lieu of the COVID-19 paid sick leave.

The legislation does not provide any direct tax or financial relief to employers for providing the additional COVID-19 paid sick leave. As such, there is no mechanism in place for employers to recoup any pay amounts associated with the additional COVID-19 paid sick leave.

The joint departments have issued yet another set of five (5) FAQs addressing coverage of COVID tests under health plans. These build on the last FAQ release.

The full FAQ is fairly readable and available here. This article attempts to summarize the most critical guidance in as few words as possible.
 

Health Plans and Self-Funded Plans

Importantly, this guidance applies to health plans (insurers) and to self-funded plans. The guidance is not directly actionable for employers with fully insured plans, but it is important to be aware of the guidance for underlying health plans. Self-funded plans must address these issues directly.
 

Q1: Direct to Consumer COVID Tests

The safe harbor has been revised to allow significant flexibility to plans in how they provide access to over-the-counter (OTC) COVID-19 tests. Plans must ensure participants have adequate access with no upfront out-of-pocket expenditure. This generally means there is at least one direct-to-consumer shipping mechanism and at least one in-person mechanism.
 

Q2: Supply Shortages

Plans will not face enforcement action if they are temporarily unable to provide adequate access to OTC COVID-19 tests through their direct coverage program due to a supply shortage. In that case, plans may continue to limit reimbursement to $12 per test (or the full cost of the test, whichever is lower) for tests purchased outside of the direct coverage program.
 

Q3: Suspected Fraud

While medical management is prohibited, plans are permitted to address suspected fraud and abuse related to the reimbursement of OTC COVID-19 tests purchased by a participant from a private individual or via online auctions, resale marketplaces, or resellers. Specifically, plans may disallow reimbursement for tests that are purchased by a participant from a private individual via an in-person or online person-to-person sale, or from a seller that uses an online auction or resale marketplace. (Resale marketplaces refer to services like eBay, Facebook Marketplace, etc. In-person sales refers to purchasing from a friend or other contact that may have a supply of tests.)
 

Q4: Self-Collected/Lab Processed Tests

Plans are not required to provide coverage for tests that use a self-collected sample, but require processing by a laboratory or other health care provider to return results (such as home-collection PCR tests that can be purchased directly by consumers). However, when a test is ordered by an attending health care provider, such a test must be covered.
 

Q5: Reimbursement Through FSA/HRAs

While the cost of OTC tests purchased by an individual is a medical expense and thus generally reimbursable by a health FSA, HRA, or HSA, an individual cannot be reimbursed more than once for the same medical expense. Therefore, the cost (or the portion of the cost) of OTC COVID-19 tests paid or reimbursed by a plan cannot be reimbursed by a health FSA, HRA, or HSA. If an individual mistakenly receives reimbursement from a health FSA, HRA, or HSA, corrective measures should be initiated.

On January 10, the Departments of Labor, Health and Human Services (HHS), and the Treasury issued Frequently Asked Questions (FAQs) that require group health plans/insurers to cover the costs of at-home, over-the-counter COVID-19 tests. Key requirements are as follows:
 

• Tests must be approved by the U.S. Food and Drug Administration (FDA).
• Tests must be purchased on or after January 15, 2022.
  • The requirement will continue through the Coronavirus public health emergency period, which is expected to extend to at least April 15, 2022.
• Tests can be purchased online, at a pharmacy, or at a retail store.
• Each individual may purchase up to eight COVID-19 tests per month (note the per-test limit, not per-kit limit; kits may contain multiple tests).
• Plans and insurers may provide tests through existing pharmacy or direct delivery networks, as long as they take reasonable steps to ensure access.
  • If individuals obtain tests outside of the above channels, tests may be limited to reimbursement of $12 per test (or the cost of the test if under $12).
• Tests for employment purposes are not required to be covered.
• There is currently no limit on COVID-19 tests ordered or administered by a healthcare provider.

Note this blog only covers the federal mandate, not any state-specific mandates.
 

How will insurance carriers comply?

Vita is working with all major insurance carriers to identify more details for fully insured plans. Vita clients are encouraged to reach out to their benefits account management teams if there are any questions about how specific insurance carriers are receiving claims or processing reimbursements. Below are links to major medical carriers’ coronavirus pages:
 

• Aetna
• Anthem Blue Cross of CA
• Blue Shield of CA
• Cigna
• Kaiser
• UnitedHealthcare

A candid and agile culture is essential for organizations to effectively lead and engage their people during the COVID-19 pandemic. It’s more critical than ever to adapt to the changing environment of new compliance concerns, managing updated leave and remote work policies, considerations for working parents, general mental health and wellbeing, and much more.

Listen to this podcast featuring Jyoti Khadgawat (Head of HR @ Smule), Charles Reader (Chief Talent Officer @ California Health Care Foundation), Erik Hansen (President @ Vita), and moderator E.J. Nham (Sr. Global Benefits Manager @ Rubrik) on how they are tackling these issues, strategies they've implemented, and what they've learned in the process.

Referenced apps and programs:

• Slack - #watercooler channel
• Donut - virtual coffee with leaders; randomized groups 
• Smule - virtual sing together's
• Zoom - break-out rooms
• Headspace, Calm, Happify, Woebot - wellness programs
• Task Human - free wellness sessions
  
  

On Monday, April 6, the DOL released new regulations with detailed guidelines for Paid Sick Time and Paid Family Leave under the FFCRA. The guidance provides important details for employers on how sick time and leaves are to be administered. The following is a summary of the materials added to our COVID-19 Employer Playbook:

• IRS Form 7200 released for claiming advance tax credit when leave payments are greater than current tax payments.
• Clarification that if an employer has no work available, then neither paid sick time nor paid family leave are available to employees.
• Clarification that if an employee can work from home, then no COVID-19 leave is available based solely on a Shelter in Place order.
• Specific details are provided relative to when COVID-19 leaves are available: self-quarantine, physician ordered quarantine, symptoms vs. no symptoms, waiting for test results, etc.
• Clarification that leave to care for a child requires that another suitable individual, such as a co-parent co-guardian, or the usual childcare provider is not available to provide childcare.
• Guidance that sick time calculation for part time employees with variable schedules is now determined based on 6-month period (not two weeks)
• Clarification is provided that an employee may take a combined 12-weeks maximum FMLA under regular FMLA and COVID-19 paid family leave.
• Employer requirements for an employee’s “reasonable notice” is defined.
• Required documentation of sick time and leaves is outlined.
• Clarification that FFCRA leaves are job protected, but not “layoff protected.”
• Clarification that employers must retain COVID-19 leave documentations for four (4) years.

In addition, we have added a short section outlining the new DHC guidance that temporarily relaxes I-9 documentation requirements for employers with remote work arrangements due to Shelter in Place orders.

One of the main tenants I remember from Finance 101 is, “there is no free lunch.” The approval of the Federal government’s Coronavirus Aid, Relief, and Economic Security (CARES) Act, which includes the Payroll Protection Program (PPP), has provided multiple avenues for small businesses affected by the spread of COVID-19 to “eat for free,” but it’s important that we remember that it’s on our own dime (this is owned by the future American Taxpayers).

A mentor of mine helped me understand that the scale of this program is more than double the inflation adjusted value of FDR’s New Deal; which should help us all realize that we need to engage with this aid responsibly.

With that said, I hope this brief article helps you understand the steps that you can take to provide your business with the aid required to maintain payroll and protect your people.

More detail on all things COVID-19 can be found at our curated landing page.

Who should I lean on to help my company with this program?

We recommend reading the content available from the first two sources and connecting with a qualified SBA lender for further guidance. The document provided by the U.S. Chamber of Commerce is very useful for understanding your business’ eligibility and the steps required to calculate your loan amount.

• U.S. Chamber of Commerce Flyer
• U.S. Department of Treasury
• Find a Qualified SBA Lender

Gray Areas:

The notes below are not intended as legal advice and are anecdotal descriptions of our current understanding of the landscape:

• My firm has less than 500 employees, but we are a venture backed start-up, or formerly private company that changed ownership via private equity, does that change my eligibility?
  • Eligibility will be specific to your ownership details, but in general, companies with this financial structure may be disqualified from the PPP.
• If I am a member of a Professional Employer Organization (PEO) ex. TriNet, TotalSource, Sequoia One, Insperity, etc., am I disqualified?
  • Our understanding, based on our correspondence with multiple vendors, is that PEO clients are not disqualified from applying for relief through the PPP.

Additional regulations are anticipated in the very near future. We will include updates at our COVID-19 Resource Center as they occur.

Congress has passed, and the President has signed, legislation intended to ease the economic consequences stemming from the COVID-19 pandemic. The legislation is titled Families First Coronavirus Response Act, H.R. 6201. It includes a number of provisions addressing social concerns as well as four provisions that directly impact employers and group health plans.

1. Coverage Mandate – Free COVID-19 Testing
2. Paid Sick Leave for Employees
3. Expanded FMLA with Paid Leave
4. Employer Tax Credits
   
   

Coverage Mandate – Free COVID-19 Testing

Group health plans and insurers must cover FDA-approved diagnostic products to detect the virus that causes COVID-19.

No Cost Share
The testing benefits must be provided without any cost-sharing, preauthorization, or other medical management requirements. Coverage requirements include related services furnished during urgent care, emergency room, or in-person or tele-health provider visits that result in an order for or administration of a covered diagnostic test.

Impacted Plans 
This requirement applies to all health plans. This includes self-funded plans and fully insured plans, as well as to ACA grandfathered plans. However, it appears that excepted benefit plans and retiree-only plans are not subject to this provision.

Effective Date and Duration 
The mandate is effective from the date of enactment for the duration of the public health emergency declared by the Secretary of HHS.

Paid Sick Leave for Employees

Employers with fewer than 500 employees (as well as federal and state employers of any size) must provide paid sick time to employees who are unable to work (or telework) for specified virus-related reasons.

Eligibility for Sick Leave
Ten (10) days of paid sick time must be provided to full-time employees. Part-time employees are entitled to sick time based on their average hours worked over a two-week period. Benefits are available immediately regardless of the employee’s length of employment.

Sick Leave Maximum Benefit
Benefits are calculated based on the employee’s regular rate of pay and the number of hours the employee would otherwise be normally scheduled to work. The maximum benefit varies based on the reason for absence as outlined below:

Employee Who Is: (1) subject to a quarantine or isolation order, (2) advised by a health provider to self-quarantine, or (3) experiencing symptoms and seeking diagnosis.
Pay Rate: 100% of regular pay  
Maximum Daily Benefit:  $511 per day 
Maximum Total Benefit:  $5,110 total

Employee Who Is: Caring for an individual described in category (1), (2), or (3), caring for a son or daughter whose school or place of care has been closed.
Pay Rate: 66.67% of regular pay 
Maximum Daily Benefit:  $200 per day 
Maximum Total Benefit:  $2,000 total

Additional Details
Employers may not require that an employee use any other paid time program offered by the employer before using this sick leave. Additionally, the paid sick time does not carry over to the following year. Employers are also not required to reimburse employees for paid sick time not used by the employee when the employee leaves the job.

Effective Date and Duration
The effective date of the paid sick leave mandate is no later than 15 days after enactment (March 18, 2020).The mandate expires December 31, 2020.

Expanded FMLA with Paid Leave

The legislation includes the Emergency Family and Medical Leave Expansion Act, which provides a temporary expansion of the FMLA to cover a new category of leave related to COVID-19. Employers with fewer than 500 employees are required to provide paid leave due to the public health emergency.

Eligibility for Paid Leave
The emergency leave generally is available when an employee is unable to work (or telework) due to a need for leave to care for a son or daughter under age 18 because a school or place of care has been closed, or a childcare provider is unavailable, due to a COVID-19 public emergency declared by a federal, state, or local entity. To be eligible, employees must have been employed for at least 30 days (rather than the standard 12-month period for other types of FMLA leave). Similarly, the 50 employees within a 75-mile radius requirement does not apply.

Paid Leave Benefit Amount
Benefits are calculated based the employee’s regular rate of pay and the number of hours the employee would otherwise be normally scheduled to work.

• 67% of regular pay
• Maximum benefit = $200 per day
• Aggregate Maximum = $10,000 per employee

The first 10 days of leave may be unpaid. After Day 10, paid leave must be provided.

Duration
The maximum benefit of $200 per day results in 50 days of paid leave. A daily rate of $100 per day (approximately $4,500 in monthly compensation) results in 100 days of paid leave.

Additional Details
Notably, no changes have been made to the FMLA’s health benefit provisions. However, the additional leave rights may result in more employees taking FMLA leave, which will affect administration of group health plans. Employers should review their policies and procedures in light of the changes (e.g., new definitions and temporary timeframes). Certain exemptions and special rules apply, and a tax credit may be available (see below).

Effective Date and Duration
The effective date of the paid FMLA paid leave extension is no later than 15 days after enactment (March 18, 2020). The mandate expires December 31, 2020.

Tax Credits for Employers

The bill provides refundable tax credits to help employers cover the cost of providing these new paid leave benefits. The credits apply against the employer portion of Social Security taxes due and are equal to 100% of the qualifying paid leave wages paid by the employer, up to certain limits.

Tax Credits – Paid Sick Leave
The sick leave credit is limited to $511 per day per employee if qualified sick leave was taken by the employee for his or her own needs or $200 per day per employee if qualified sick leave was taken to provide care for others. In either case, the maximum number of days that may be taken into account in calculating the tax credit is 10 per employee, across all quarters.

Tax Credits – Paid FMLA Leave
The credit is limited to $200 per day per employee, with an aggregate $10,000 cap per employee, if taken for qualified family medical leave.

Tax Credits – Health Plan
The FMLA-related and emergency paid sick leave credits can be increased to include amounts employers pay for an employee’s health plan coverage while the employee is on leave.

Timing of Credit
Tax credits are computed on a quarterly basis and are available for Q2, Q3, and Q4 2020. Because of the effective date, (15 days after action by the Secretary), enactment will take too long for the credit to have any application in Q1.

No Double-Dipping
To the extent that a covered employer elects to receive the credit, the credit amount must be taken into the employer’s gross income, which effectively eliminates any potential double benefit because the employer will have deducted the sick leave wages it paid.

Wages and Taxation
The qualified sick leave wages paid are not “wages” for the employer-portion of the Social Security tax. The legislation has no effect on the employee-portion of the Social Security tax, nor does it have any effect on employer or employee-portion of the Medicare tax.

Notices and Procedures

An employer must post a notice for employees about the requirements of the law.

After the first workday that an employee receives paid sick time, the employer may require the employee to follow “reasonable notice” procedures in order to continue receiving the paid sick time. “Reasonable notice” is not defined in the bill.

The employer may not require that the employee find or search for a replacement to cover the hours the employee will be on sick leave.

What About 500+ Employers?

Although employers with 500 or more employees are exempt from the paid sick leave mandate in this bill, it is useful for all employers to understand the approach taken by Congress since additional legislation may still be introduced to cover larger employers.

Also, we do not yet know whether related employers (such as members of a controlled group) may or must aggregate employees to reach the 500-employee threshold, or if the 500-employee threshold is determined on an entity-by-entity basis without considering whether the entities are related. We anticipate implementing guidance from the Department of Labor and/or the Internal Revenue Service on this issue in the next two weeks.

The Crystal Ball . . .

In addition to legislation, administrative actions are likely to affect employers and their benefit plans over the coming weeks and months. Action is likely at the federal, state, and local levels. Given the nature of the emergency, most of these actions will demand immediate attention, so it is important to stay closely attuned. The team at Vita will keep you apprised of critical benefits-related issues.

Vita clients in need of sample language to update their policies or handbooks can refer to ThinkHR. If you need assistance with your access, please reach out to your Vita representative for assistance.

On Thursday, March 12th, California Governor Gavin Newsom issued a new executive order enhancing benefits for employees diagnosed with COVID-19. Those individuals who are unable to work due to having been exposed to COVID-19 will now have the 7-day waiting period waived for disability and unemployment insurance. CA SDI provides short-term benefit payments to eligible workers who have a full or partial loss of wages due to a non-work-related illness, injury, or pregnancy. Benefit amounts are approximately 60-70 percent of wages (depending on income) and range from $50-$1,300 a week. 

Please note that SDI claims are accepted for both being diagnosed and being exposed to COVID-19 (as certified by a medical professional).  For more information, please see the CA-SDI website here: https://edd.ca.gov/about_edd/coronavirus-2019.htm 

If you have questions about this change as it relates to your employees and your private disability contracts, please reach out to your Vita representative. 

Recent Market Volatility

While market corrections are never pleasant, they are something investors should expect to happen from time to time, especially as saving for retirement is a long-term process. We believe that one of the best ways to manage risk, and our reaction to it, is to have a well-diversified portfolio. 

As Co-Fiduciary on our clients’ 401(k) plans, Vita Planning Group works closely with plan sponsors and recordkeepers to ensure the mutual funds available to participants are well managed and offer a diverse range of market sectors and investment strategies. While this cannot prevent short-term losses in any portfolio (or guarantee a profit), we encourage participants to look at retirement savings as a long-term process and to base investment decisions on risk tolerance and time horizon, over that long-term. 

Perspective

It is important to remember that we have seen many sharp market corrections from which we have recovered: most recently the crash of technology stocks in the early 2000’s, the mortgage crisis of 2008/2009, and now the Coronavirus (Covid-19) outbreak. 2020 is also an election year, which is likely to add to the already volatile markets.   

There have been at least 10 serious health events like Covid-19 (e.g. SARS, Avian flu, Zika virus) since the 1990s that have caused significant downturns in global markets.¹ In 8 of those 10 events, stocks climbed more than 10% after the scare. Additionally, there have been 26 market corrections of at least a 13% decline since the end of World War II. On average it has taken four months for markets to get back to their pre-decline levels.

Closing Thoughts

Periodically rebalancing investments is an important way to help manage risk in one’s portfolio and can help one to meet his or her retirement goals. However, this should be done in a calm and methodical way and not in reaction to short-term market movements or media hysteria. 

¹Wall St. Journal Op-Ed published on March 2, 2020