In 2021, the U.S. Department of Labor (DOL) issued 3 documents outlining guidance on cybersecurity practices for benefits plans, which we discussed in a blog post at the time. The DOL recently issued revised versions of the...more
9/12/2024
/ Benefit Plan Sponsors ,
Best Practices ,
Corporate Counsel ,
Cybersecurity ,
Department of Labor (DOL) ,
Employee Benefits ,
Fiduciary ,
Guidance Update ,
Health and Welfare Plans ,
Multi-Factor Authentication ,
Passwords ,
Pensions ,
Sensitive Personal Information
Last week, the Departments of Labor, Treasury and Health and Human Services (“the Departments”) issued an FAQ about the final Transparency in Coverage rules (“TiC Rules”). This FAQ addresses compliance with cost‑sharing...more
On May 18, 2021, the IRS released Notice 2021-31 (the “Notice”) providing guidance on the temporary 100% COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”), summarized generally here. The Notice...more
In an earlier post we reviewed the end dates for the ARP COBRA premium subsidy provided by the American Rescue Plan Act of 2021 (“ARP”), and addressed the required expiration notice. This post revisits the topic in light of...more
Due to tight timelines and an initial sprint to issue the special extended COBRA election period notices by the May 31st deadline, plan administrators may not have focused on the other COBRA-related notice requirements under...more
4/22/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Premium Subsidies ,
Relief Measures ,
Special Election
The American Rescue Plan (“ARP”) offers a special 60-day election period for certain individuals who previously declined or discontinued COBRA coverage (“Assistance Eligible Individuals” or “AEIs,” as defined in ARP). These...more
4/22/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Premium Subsidies ,
Relief Measures ,
Special Election
The DOL recently issued Field Assistance Bulletin 2021-01, blessing the PBGC’s Missing Participant Program as an additional method of addressing a perennial issue in 401(k) terminations – the problem of missing participants...more
The DOL recently provided retirement plans with a new method to comply electronically with certain participant disclosure and notice requirements. See our blog post outlining the new DOL rule. This new method adds to the...more
8/6/2020
/ Department of Labor (DOL) ,
Disclosure Requirements ,
Electronic Disclosure ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
IRS ,
Notice Requirements ,
Pensions ,
Plan Administrators ,
Retirement Plan ,
Safe Harbors
On April 29, 2020, the U.S. Departments of Labor (Employee Benefits Security Administration, “EBSA”) and Treasury (IRS) published a final regulation, and EBSA issued a package of guidance and relief, for employee benefit...more
Editor's Overview -
As the summer draws to a close, this month's Newsletter previews three cases that the U.S. Supreme Court already has agreed to hear that ought to be of particular interest to ERISA plan sponsors and...more
8/28/2015
/ 401k ,
Actual Injuries ,
Affordable Care Act ,
Article III ,
Benefit Plan Sponsors ,
COBRA ,
Defined Benefit Plans ,
Defined Contribution Plans ,
Delta Airlines ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Duty to Disclose ,
Employee Retirement Income Security Act (ERISA) ,
Equitable Relief ,
Fair Credit Reporting Act (FCRA) ,
Fiduciary Duty ,
FIfth Third Bancorp v Dudenhoeffer ,
Final Rules ,
HDHP ,
Health Insurance ,
Health Plan Sponsors ,
HSA ,
IRS ,
Medicaid ,
Medicare ,
Montanile v Board of Trustees ,
Non-Grandfathered Health Plans ,
PBGC ,
Penalties ,
Preemption ,
Reimbursements ,
Reporting Requirements ,
SCOTUS ,
Section 510 ,
Spokeo v Robins ,
Standing ,
Stock Drop Litigation ,
Subrogation ,
Summary of Benefits and Coverage ,
Tax Credits ,
Trade Adjustment Assistance ,
Trade Preferences Extension Act (TPEA) ,
U.S. Treasury
As promised in the FAQ issued on March 30, 2015, the U.S. Departments of the Treasury, Labor and Health and Human Services (the Departments) have issued final regulations regarding the summary of benefits and coverage (SBC)...more
7/13/2015
/ Affordable Care Act ,
Compliance ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Health Insurance ,
IRS ,
Medicare Advantage ,
Minimum Essential Coverage ,
Minimum Value Plans ,
New Regulations ,
Summary of Benefits and Coverage ,
Third-Party ,
U.S. Treasury