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My Insurance Doesn’t Cover That? Agency Guidance on “Junk Insurance”

Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance...more

FICA Tax Avoidance Wellness Program Viewed Unfavorably by 87,000 New IRS Agents

Seyfarth Synopsis: Just like a bad penny, schemes promising employers ways to reduce their FICA tax burden, and maybe their employees’ income tax burden at the same time, keep popping up with a slightly different burnish on...more

Final Rules Fix Family Glitch

Seyfarth Synopsis: Recently, on October 11, 2022, the Internal Revenue Service (IRS) issued final regulations which finalized changes to affordability of employer coverage for the family members of employees under Internal...more

IRS Releases Extensive Guidance on ARPA COBRA Subsidy

Seyfarth Synopsis: On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”), which requires plan sponsors to provide free COBRA coverage from April 1, 2021 through September 30, 2021, to...more

Waistbands Aren’t the Only Thing Requiring Flexibility During the Pandemic: IRS Clarifies Guidance on Latest FSA Provisions and...

Seyfarth Synopsis: The Consolidated Appropriations Act of 2021 (“CAA”) offers significant relief for employers sponsoring flexible spending accounts (for a more detailed description of those changes, check out our alert). ...more

One-Year Expiration of Outbreak Period: Pandemic Rages On, But It’s (Probably) Time to Pay Your COBRA Premiums

Seyfarth Synopsis: As you’ll recall, last Spring, the DOL and IRS issued guidelines providing relief from certain deadlines for employee benefit plans, retroactive to March 1, 2020 (i.e., the beginning of the COVID-19...more

All Bets Are Off: IRS Issues New Playbook for Section 125 Plans During Pandemic

On May 12, the IRS released Notices 2020-29 and 2020-33, which collectively provide various forms of relief under the existing IRC Section 125/129 rules in light of the COVID-19 pandemic. ...more

Months After Ordering Plans to Disregard Sub-Regulatory Guidance, Trump Administration Learns to Love the Informal FAQs

Seyfarth Synopsis: On April 11, the IRS, DOL and HHS issued a series of FAQs clarifying the scope of the FFCRA/CARES Act mandates relating to COVID-19 testing for group health plans and health insurance issuers. This post...more

More Viral Benefits News

Seyfarth Synopsis: One of many COVID-19 benefits-related concerns focused on the ability of individuals covered under High Deductible Health Plans to have services to diagnose or treat the coronavirus covered before their...more

Paying Employees to Opt Out of Insurance? BEWARE

Seyfarth Synopsis: That “win-win” in contract negotiation wherein employees are paid to opt out of employer insurance has become much more complicated thanks to the IRS. Basically, if bargaining parties do not follow new IRS...more

Issue 98: Year-End Agency FAQs Address Many Unanswered ACA Concerns

This is the ninety-eighth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

Issue 91: Agencies Issue Guidance on Wraparound Coverage and Supplemental Insurance Products as Excepted Benefits

This is the ninety-first issue in our series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of certain aspects...more

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