In a March 2023 ruling, a Texas federal district court vacated all actions taken by the Departments of Labor (“DOL”), Health and Human Services (“HHS”), and Treasury (collectively, the “Departments”) to implement or enforce...more
We are just past the “official” start of summer, which means it is time for sponsors of retirement plans and many health and welfare plans to think about preparing and submitting Form 5500. In this post on the All Things HR...more
Recent guidance from the Department of Labor (“DOL”), Health and Human Services (“HHS”) and Treasury (the “Departments”) provides limited enforcement relief from the summary of benefits and coverage (“SBC”) disclosure rules...more
The Department of Labor (“DOL”) has proposed a new safe harbor to allow employers to furnish information to participants and beneficiaries subject to ERISA....more
With immigration enforcement in the news, some employers may be wondering what responsibilities they have related to their retirement plans, if an employer discovers that an employee lacks documentation authorizing the...more
As I have discussed previously on Dickinson Wright’s All Things HR Blog, the Department of Labor’s (“DOL”) disclosure regulations with respect to electronic disclosure of ERISA plan-related documents and notices are woefully...more
It is well known by employers that nonqualified deferred compensation (“NQDC”) plans that are established to provide unfunded deferred compensation benefits to a select group of management or highly compensated employees...more
The summary plan description (“SPD”) and disclosure regulations provided by the Department of Labor (“DOL”) are spread across six regulatory sections. They are voluminous....more
Most employers are familiar with the requirement to prepare and distribute a summary plan description (“SPD”). Many employers, however, assume that Department of Labor (“DOL”) disclosure requirements are consistent with the...more
On November 24, 2017, the Department of Labor (“DOL”) Employee Benefits Security Administration (“EBSA”) formally delayed the applicability date of previously issued final regulations imposing new claims procedures to...more
On May 22, 2017, Secretary of Labor Jim Acosta announced that, after having been delayed 60 days, the Department of Labor’s (“DOL”) Conflict of Interest Rule (“Fiduciary Rule”) will largely apply on June 9, 2017. At that...more
Despite guidance from the Internal Revenue Service (“IRS”), the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) indicating the prohibition of the practice under the Affordable Care Act...more
5/29/2015
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