I blogged recently about IRS and Department of Labor (DOL) guidance restricting the ability of employers to subsidize individual health insurance premiums for their employees after December 31, 2013. That IRS and DOL guidance...more
On Friday, September 13, 2013, the IRS released Notice 2013-54 and the DOL issued Technical Release 2013-03 in substantially identical form. This guidance, which is generally effective January 1, 2014, provides much needed...more
You know that many ERISA governed plans provide basic life insurance benefits.
But what happens when the plan offers employees the choice to purchase supplemental life insurance? If the employee pays the entire premium...more
You already know that an individual disability policy may nevertheless be governed by ERISA, even when the employee pays her own premium. This can occur when the employees benefit from a rate structure or premium discount...more
Can ERISA apply to the claims made on individual policies purchased with discounted premiums? YES. ...more
So yesterday, I made a convincing case that employees who smoke outside the workplace can’t be treated differently than your non-smokers. ...more