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Medicare Part D Creditable Coverage Notices are Due Before October 15

Group health plan sponsors are required to send annual notices (as well as at other particular times) to individuals who are eligible for Medicare Part D that explain whether the health plan’s prescription drug coverage is...more

New DOL Guidance and Model Notices Assist Employers with Their New COBRA Subsidy Obligations

As we previously reported, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes a six-month COBRA premium subsidy whereby the federal government subsidizes 100% of the COBRA premium during the period of April...more

Recent COBRA Developments Require Review of COBRA Policies and Practices

As summarized below, recent updates to Model COBRA Notices, extensions of deadlines as a result of COVID-19, and an uptick in class action lawsuits stemming from allegedly deficient COBRA Notices, will require a review of...more

DOL Publishes Helpful New Electronic Disclosure Rules for Retirement Plans

Embracing 21st century technology, the U.S. Department of Labor (DOL) recently published a final rule that provides a new safe harbor for electronic distribution of disclosures to retirement plan participants and...more

Plan’s Failure To Notify Participant Of Deadline To File Suit Left Limitations Period Unenforceable

A federal district court in Utah recently held that a health plan’s 180-day limitations period for filing suit following a claim denial on appeal was unenforceable because the plan’s final adverse benefit determination letter...more

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