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DOL Issues (Some) Additional Guidance on the Fiduciary Investment Advice Rule and Best Interest Contract Exemption

The US Department of Labor (DOL) has issued its first set of FAQs under the fiduciary investment advice rule (the “Rule”) and related prohibited transaction exemptions. In general, the Rule provides that parties providing...more

IRS Continues to Expand, Encourage and Simplify Correction Program in 2015 Updates to EPCRS

In spite of a plan sponsor's best efforts, errors and failures in administering a retirement plan occasionally come to light. We hear about these errors and failures usually following a change in administration, service...more

Novel IRS Guidance on HRAs, VEBAs and Domestic Partner Benefits

The Internal Revenue Service (IRS) recently provided guidance on several issues never before addressed. The guidance came in the form of a Private Letter Ruling (PLR), to be released later this year to the public under the...more

3/3/2014  /  FOIA , HRA , IRS , Private Letter Rulings

Defense of Marriage Act Ruling Has Multiple Effects on Benefit Plans

On June 26, the US Supreme Court ruled in United States v. Windsor that Section 3 of the federal Defense of Marriage Act (DOMA) is unconstitutional. The Supreme Court ruled that DOMA’s federal exclusion of state-recognized...more

Departments Release Waiting Period Regulations for Group Health Plans

On March 18, the Departments of Health and Human Services, Labor and Treasury (the Departments) issued joint proposed regulations on the Patient Protection and Affordable Care Act’s prohibition of waiting periods of longer...more

IRS and US Department of Labor Continue to Expand, Encourage and Simplify Correction Programs in 2013 Updates to EPCRS and DFVCP

Plan sponsors know that errors and failures in administering a retirement plan happen. All too often, changes in administrators, service providers and other staff uncover errors and compliance problems that should be...more

IRS Releases Proposed and Final Regulations regarding Health Insurance Premium Tax Credits

On January 30, the Internal Revenue Service released proposed and final regulations regarding the health insurance premium tax credit and the requirement that an employer maintain minimum essential coverage under the...more

HHS Releases Language for Use in Updating Business Associate Agreements

On January 25, the Department of Health and Human Services (HHS) published its highly anticipated Health Insurance Portability and Accountability Act (HIPAA) Omnibus Final Rule (Final Rule). The Final Rule covers many topics,...more

Significant New Fees for Group Health Plans in 2014-2016

The Department of Health and Human Services (HHS) issued proposed regulations in the Federal Register on December 7 which provide guidance regarding the Transitional Reinsurance Program (the Program). The Program will be...more

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