Keep those Plan documents and amendments.
You will always need them.
Plan sponsors aren't the greatest keeper of plan records because as a plan fiduciary, they think they get too many reports, prospectuses,...more
The OIG recently released a report summarizing the details of its study regarding compliance with the requirement that physicians (or certain practitioners working with them) who certify beneficiaries as eligible for Medicare...more
Beginning on July 1, 2014, employers in Ontario will have an added responsibility of ensuring that all workers and all supervisors in all workplaces that fall subject to the Ontario Occupational Health and Safety Act (OHSA)...more
As regularly reported in the news, the crackdown on employers by the federal government continues. If your company is targeted and I-9 violations are discovered, civil fines for simple paperwork violations – even if no...more
The term “deer in the headlights” explains the mental state of a person who shows behavioral signs that remind us of a deer subjected to a car’s headlights where the deer is in such panic that they show no motor reaction to...more
Today’s Electronic Health Record (EHR) technologies feature many tools that help providers practice more efficiently and allow them to spend more time caring for patients. However, the federal government recently has posted...more
Many of us in the U.S. legal community know that developing and implementing a defensible document retention policy is important, if not crucial, to a company’s data management. It can speed up the procedures in, or reduce...more
A recent decision by the Seventh Circuit in Zayas v. Rockford Memorial Hospital highlights for employers the importance of documenting disciplinary actions taken with employees. Despite the plaintiff's evidence of...more
For sales tax purposes, fuel vendors are required to obtain valid exemption certificates for all exempt nonresidential sales of fuels that are not subject to fuel taxes. Although the residential use of fuel is not subject to...more
In January 2014, CMS released a Special Edition Article of MLN Matters to clarify the documentation requirements for Home Health Prospective Payment System (HH PPS) Face-to-Face Encounters. CMS found that insufficient...more
This post is the fifth in an ongoing series about maximizing a party’s chances of prevailing on appeal. Filing a proper and timely notice of appeal is the first important task in the appellate process. Once a notice of...more
The Massachusetts Division of Banks recently amended 209 CMR 18, "Conduct of the Business of Debt Collectors and Loan Servicers." The final amended regulations clarify and establish new standards of conduct for debt...more
Earlier this year the IRS issued drafts of the 2013 Form 990, Return of Organization Exempt From Income Tax, and 2013 Form 990 Instructions. Although there were no major changes to the Form 990, there were several changes and...more
On November 27, HUD issued Mortgagee Letter 2013-42, granting an extension of time to Title I and II lenders and mortgagees with a December 31, 2013 fiscal year end to submit required materials and fees for annual...more
On November 20, the FHFA Office of Inspector General (OIG) issued a report critical of Fannie Mae’s oversight of its short sale process and the servicers who participate in that process. The OIG determined—based on a review...more
Preventive law is a prime component of our business law philosophy. As with doctors who prescribe preventive steps to avoid illness, we counsel our business clients to insure compliance with corporate formalities and to...more
CMS has released its responses to eight frequently asked questions [PDF] regarding its Self-Referral Disclosure Protocol (SRDP). The questions fall into three categories, listed below, and respond to issues that are often...more
- Co-financing by conventional lenders and Islamic compliant financiers is increasingly common as businesses seek multiple sources of funding.
- The structural differences between these tranches mean that issues...more
The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies.
New Provisions of French Law -
Provisions Already Adopted -
On September 23, 2013, Covered Entities and Business Associates must be compliant with the final Health Insurance Portability and Accountability Act (HIPAA) Omnibus Rule (the “HIPAA Final Rule”). The HIPAA Final Rule modified...more
A Washington drywall company recently learned the hard way that a partially completed I-9 form is insufficient to avoid costly penalties. The company was fined over $280,000 by the Department of Homeland Security’s...more
The CFPB has issued a bulletin to companies that furnish information to consumer reporting agencies (CRA) reminding them of their obligation under the Fair Credit Reporting Act (FCRA) to investigate consumer disputes...more
The OECD has issued the “White Paper on Transfer Pricing Documentation” outlining ideas for new global standards for the annual transfer pricing documentation exercise required by more than 60 countries. ...more
In Florida, it is well established that the original promissory note must be surrendered to the court as a condition of its enforcement. What do you do when you cannot find the original promissory note?...more
A substantial number of business policyholders purchased historical insurance coverage from one of the Lumbermens Companies, which include Lumbermens Mutual Casualty Company, American Manufacturers Mutual Insurance Company,...more
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