Automatic Enrollment

News & Analysis as of

What’s Cooking at the General Assembly in 2016 (Part II)

So last week I provided a recap of a few of the labor & employment law bills still being kicked around the legislature. From talking with a few folks in on the process, here are some other bills to keep an eye on (whether in...more

Do you need to take action before the end of contracting-out?

The end of contracting-out and the introduction of the new single-tier State Pension on 6 April 2016 is now just over a month away and there are a number of issues that employers and trustees of schemes containing...more

Auto-enrolment update – case law and trigger changes

Auto-enrolment update - Key points: The Queen on the application of Fleet Maritime Services (Bermuda) Limited v. The Pensions Regulator [2015] EWHC 3744 confirms when peripatetic (basically "mobile") workers, who...more

The ERISA Litigation Newsletter - December 2015

Editor's Overview - In this month's newsletter, we focus on the recent wave of guidance and case law related to the Affordable Care Act. We also discuss IRS Notice 2015-86, which provides guidance on the application of...more

ACA Outlook: What Will 2016 Hold for the Affordable Care Act and Employers?

For many employers, 2016 will bring new requirements and challenges with respect to compliance with the Affordable Care Act (ACA).  However, their burden in years beyond 2016 may very likely diminish because of recent changes...more

The Autumn Statement – auto-enrolment tweaks and a wait till spring...

Background - Another autumn means another Autumn Statement. This year's statement by the Chancellor was focused on things other than pensions – the U-turn on tax credits, infrastructure spending and house-building, and...more

Bipartisan Budget Act of 2015 Repeals ACA Automatic Enrollment Provision

Despite a marked lack of success for efforts in Congress and through the courts to repeal the Patient Protection and Affordable Care Act of 2010 (ACA) completely, or substantially interrupt its implementation, the Bipartisan...more

Automatic Enrollment Requirement Repealed

Good news! On November 2, 2015, President Obama signed the Bipartisan Budget Act of 2015 into law and repealed Section 18A of the Fair Labor Standards Act, enacted as part of health reform. Section 18A required employers...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 17 of 24): Reporting for Offers of Coverage and...

The recently enacted Bipartisan Budget Act of 2015 repealed Section 1511 of the Affordable Care Act (ACA), which generally would have required employers with more than 200 full-time employees to automatically enroll new...more

RIP, Automatic Enrollment

Sixty-seven months ago, Congress ordered employers of 200 or more full-time employees to switch from opt-in to opt-out enrollment. See 29 U.S.C. § 218a. But the enforcement agencies could not write a rule that did more good...more

Bipartisan Budget Act of 2015 Includes Pension and ACA Provisions

On November 2nd, the President signed legislation that will raise the debt ceiling through March 2017. The legislation includes important provisions relating to pension funding, PBGC premiums, and the Affordable Care...more

Bipartisan Budget Agreement Triggers New Audit Rules for Partnerships; Repeals ACA Automatic Enrollment

On November 2, 2015, President Obama signed into law the Bipartisan Budget Agreement of 2015, H.R. 1314, which, in addition to lifting mandatory spending caps and raising the federal debt ceiling, has repealed the Affordable...more

Budget Legislation Repeals Affordable Care Act’s Automatic Enrollment Requirement for Large Employers

The Bipartisan Budget Act of 2015, Pub. L. No. 114-74, which was signed by President Obama on November 2, 2015, included a little-publicized provision that repealed the Affordable Care Act’s automatic enrollment requirement. ...more

November and December 2015 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...more

Employee Benefits Provisions of the Bipartisan Budget Act of 2015

The Bipartisan Budget Act includes the following important employee-benefit related provisions: - It repeals the automatic enrollment mandate of the Affordable Care Act. Under the ACA, employers with more than 200...more

Health Care Update - November 2015

Ways & Means Leadership Changes – Health Policy Implications Looming: As Congress pushes forward with a two-year budget deal, and new Speaker Paul Ryan begins his tenure as the top Republican in the House of...more

ACA Automatic Enrollment Mandate Repealed by Bipartisan Budget Act

On Monday, November 2nd, the President signed the Bipartisan Budget Act of 2015 (BBA). Some legislators had hoped that a budget deal would at least include a repeal of the controversial 40% excise tax on high-cost health...more

Automatic Enrollment for Health Plans Has Been Repealed

Budget legislation signed into law by President Barack Obama on November 2, 2015, the Bipartisan Budget Act of 2015, repeals the controversial automatic enrollment provision under the Affordable Care Act (ACA). Section 18A of...more

Pending Budget Deal Includes Medicare Sequestration Extension, Other Medicare/Medicaid Cuts

Outgoing House Speaker John Boehner and the Obama Administration have reached agreement on a two-year, $80 billion budget/debt-ceiling deal that includes Medicare and Medicaid “offsets” to finance other spending. For...more

Federal District Court Articulates Criteria for Effective Presentation of Electronic Contracts

In Berkson v. Gogo LLC, 2015 WL 1600755 (E.D. NY 2015), the Eastern District of New York denied a motion to dismiss and compel arbitration filed by an in-flight wifi provider. The provider was accused in a class action suit...more

Pensions News - July 2015

Welcome to DLA Piper’s Pensions News publication in which we report on developments in pension legislation, guidance and case law, as well as keeping you up to speed on what to look out for in the coming months. This...more

IRS Provides Helpful Updates to Retirement Plan Correction Program

The IRS has issued Revenue Procedures 2015-27 and 2015-28 (“Rev. Proc. 2015-27” and “Rev. Proc. 2015-28”), which modify the IRS’ retirement plan correction programs known as the Employee Plans Compliance Resolution System...more

Pensions News - April 2015

In This Issue: - Budget 2014 reforms - The Pensions Regulator - Legislation - Case Law - Public Service Pension Schemes - Other News - On the Horizon - Excerpt from...more

Pensions News - March 2015

In This Issue: - Budget 2014 reforms - Budget 2015 - The Pensions Regulator - Legislation - DC Charges and Governance - Case Law - HMRC - Public Service Pension Schemes - Other News - On the...more

CMS Issues Final Rule on Marketplace Auto-Enrollment

On September 5, 2014, the Centers for Medicare and Medicaid Services (CMS) published a final rule, effective October 6, 2014, that, among other things, specifies the auto-enrollment process for consumers who receive health...more

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