Sharon Freilich

Sharon Freilich

Pullman & Comley, LLC

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Latest Publications


Alert: Health Plan Update on Out-of-Pocket Limitations

The Affordable Care Act (the “ACA”) established limitations on the annual out-of-pocket costs that a health plan may impose on a participant. The U.S. Department of Health and Human Services, Department of Labor and the...more

6/19/2015 - Affordable Care Act DOL Employer Group Health Plans Health Insurance Healthcare HHS Out-of-Pocket Expenses Self-Funded Health Plans U.S. Treasury

Medical Insurance Premium Reimbursement — A Brief Reprieve for Small Employers

Some employers – particularly smaller ones – have assisted their employees to obtain health insurance by reimbursing them for the cost of insurance they purchase in the individual market. Does this practice satisfy the...more

2/23/2015 - Affordable Care Act Employee Benefits Health Insurance IRS Medicare Reimbursements Small Business TRICARE

Alert: Closing Affordable Care Act Loopholes

The U.S. Departments of Labor, the Internal Revenue Service and the Department of Health and Human Services recently issued guidance clearly stating that employers may not, without incurring penalties, reimburse employees who...more

12/1/2014 - Affordable Care Act Corporate Counsel DOL Employer Mandates HHS IRS Popular Reimbursements

IRS Announces Cost of Living Adjustment (COLA) Limits for 2015 Applicable to Retirement Plans

The Internal Revenue Service has announced the cost of living adjustments (COLA) applicable to dollar limitations for retirement plans for 2015. Several of the limits that currently apply to the 2014 plan year will change for...more

11/5/2014 - COLA Cost-of-Living IRS Pensions Qualified Retirement Plans

New Guidance – Is that Rollover Contribution Valid?

Since 1992, the ability to move retirement money from one qualified plan to another qualified plan or individual retirement account has been simplified. One hiccup in this easing process has been determining the level of due...more

4/11/2014 - DOL IRA IRA Rollovers Qualified Retirement Plans Safe Harbors

Escaping the Clutches of 409A

Employers often use non-qualified deferred compensation (“NQDC”) arrangements to motivate or reward executive and management employees. These NQDC arrangements, if properly structured, enable key employees to defer income...more

4/10/2014 - Compliance Deferred Compensation Employer Liability Issues Section 409A

Stand-Alone Health Reimbursement Arrangements May Not Be Dead After All

Many employers offer employees Health Reimbursement Arrangements (“HRAs”) to assist employees meet their health care related expenses. Often such employer funded arrangements are not “integrated” with an insured health plan,...more

1/17/2014 - Employer Group Health Plans Healthcare Reimbursements

Connecticut Law Requires Employers to Adopt Cafeteria Plans

In 2007 Connecticut adopted a law requiring employers to adopt cafeteria plans if their employees are required to pay a portion of the health insurance premium for employer-sponsored health insurance through payroll...more

12/11/2013 - Cafeteria Plans Health Insurance Healthcare Premiums

Notice to Employees About Health Insurance Exchanges Due October 1, 2013

The Affordable Care Act provides individuals with the option of purchasing health coverage through new health insurance exchanges, or “Marketplaces” that will operate in every state effective January 1, 2014 (e.g.,...more

9/20/2013 - Affordable Care Act Deadlines DOL Health Insurance Exchanges Healthcare Marketplace Notice

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