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Telehealth Coverage Reinstated for HDHP/HSAs Effective April 1, 2022

The Consolidated Appropriations Act of 2022 (“2022 CAA”), which was recently signed into law, reinstates the exception that allows high deductible health plans (“HDHPs”) to waive all or a portion of participant cost-sharing...more

UPDATE: California Releases Guidance and Required Notices for 2022 COVID-19 Supplemental Paid Sick Leave

On the eve of enforcement, California’s Department of Industrial Relations (“DIR”) released FAQs and the required poster for the state’s 2022 COVID-19 Supplemental Paid Sick Leave (“SPSL”)....more

2022 Employee Benefit Plan Limits Announced by IRS

The IRS has released the 2022 cost-of-living adjustments for limits on employee benefits with some adjustments to the 2022 rates including minor increases to the maximum contributions allowed under Code Section 415 for...more

Reminder – Medicare Part D Notices due October 15, 2021

Group health plan sponsors must provide annual Medicare Part D Notices (the “Notice” or the “Notices”) by October 15, 2021. It’s your last chance to make sure your Notices will be timely delivered and comply with the legal...more

Utilizing Wellness Programs to Incentivize COVID-19 Vaccinations

Delta Airlines made headlines this month by announcing that it will charge employees on its group health plan a $200 surcharge for failure to receive the COVID-19 vaccination. Although there is potential for conflict with a...more

IRS Updates EPCRS Correction Program for Qualified Retirement Plans

The IRS released Revenue Procedure 2021-30, a new iteration of the Employee Plans Compliance Resolution System (“EPCRS”), on Friday, July 16. EPCRS permits sponsors of eligible tax-qualified retirement plans and 403(b) plans...more

COBRA Subsidies are Revived — Last-Minute Guidance May Have Expanded Your Duties

New guidance has been issued to clarify the Subsidized COBRA obligations imposed on employers and plan sponsors by the American Rescue Plan Act of 2021 (“ARPA”). This guidance comes at the last minute, as the deadline to send...more

COBRA Subsidies are Revived — Update

The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs or had a reduction in hours (and their family...more

Additional Employee Benefits Relief in the American Rescue Plan Act of 2021

President Biden signed The American Rescue Plan Act of 2021 (“ARPA”) into law on March 11, 2021, adding new employee benefits relief and providing extensions of prior COVID-19 relief. In our prior Alert[1] we discussed ARPA’s...more

COBRA Subsidies Are Revived

The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs (and their family members) the right to continue...more

Don’t Restart the Clock Just Yet – COBRA, HIPAA, Other Deadlines Might Be Further Extended!

At the last minute, certain suspended COBRA, HIPAA and claims procedure deadlines that were set to expire on February 28, 2021 have been further extended. As we discussed last year the Department of Labor (DOL) and Internal...more

New Year, New COVID-19 Relief for Employers and Plan Sponsors (Part 3)

The Consolidated Appropriations Act, 2021, H.R. 133 (the “CAA”) signed into law by the President on Dec. 27, 2020 and a variety of IRS guidance issued in the first week of 2021 mean that employers entering the new year have...more

New Year, New COVID-19 Relief for Employers and Plan Sponsors (Part 2)

The Consolidated Appropriations Act, 2021, H.R. 133 (the “CAA”) signed into law by the President on Dec. 27, 2020 and a variety of IRS guidance issued in the first week of 2021 mean that employers entering the new year have...more

New Year, New Covid-19 Relief for Employers and Plan Sponsors (Part 1)

The Consolidated Appropriations Act, 2021, H.R. 133 (the “CAA”) signed into law by the President on December 27, 2020 and a variety of IRS guidance issued in the first week of 2021 mean that employers entering the new year...more

Are You Counting LTPTEs for Your 401(k) Plan?

The Setting Every Community Up for Retirement Enhancement Act of 2019 (the Act) made changes in the qualified plan rules for eligibility and vesting with respect to so-called “long-term part-time” employees (LTPTE). The...more

2021 Employee Benefit Plan Limits Announced by IRS

The IRS has released the 2021 cost-of-living adjustments for limits on employee benefits with some adjustments to the 2021 rates including minor increases to the maximum contributions allowed under Code Section 415 for...more

Affordable Care Act Deadlines Extended for 2020 Notices

Similar to last year, in Notice 2020-76, the Internal Revenue Service (the “IRS”) has extended the deadlines for delivery (but not filing) of the 2020 Forms 1094 and 1095 required by the Affordable Care Act (the “ACA”)....more

Reminder – Medicare Part D Notices due October 15, 2020

Group health plan sponsors must provide annual Medicare Part D Notices by October 15, 2020. Now is a good time for you to check to make sure your Notices will be timely delivered and comply with the legal requirements. Read...more

Additional COVID-19 Relief – Payroll Tax Withholding Deferral

The IRS has issued guidance (IRS Notice 2020-65) implementing the Executive Order issued in early August by the President that directs that employees be allowed to delay their payment of certain payroll tax obligations during...more

IRS Updates Model Tax Notice

Section 402(f) of the Internal Revenue Code (“Code”) requires certain information to be provided to plan participants eligible to make rollover distributions. Periodically, the IRS has issued model 402(f) notices. ...more

IRS Eases COVID Distribution Rules: More Individuals Can Withdraw or Borrow From Retirement Accounts

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) permitted coronavirus-related distributions (CRDs) from qualified retirement plans (employer plans) and individual retirement accounts and similar accounts...more

Welcome Relief in the Paycheck Protection Program Flexibility Act

This week the Senate passed the Paycheck Protection Program Flexibility Act of 2020 (the “Act”). Once signed into law by the President, the Act will make significant and welcome changes to the Paycheck Protection Program (the...more

New DOL E-Disclosure Rules Finally Bring Plan Administration Into the 21st Century

Late last week the U.S. Department of Labor (“DOL”) announced a final rule that brings retirement plan disclosures into the 21st Century by allowing widespread electronic delivery to workers (“Final E-Disclosure Rule”). ...more

Checklist for Businesses Receiving a PPP Loan — Maximize Your Forgiveness

If you are a small business that received a Paycheck Protection Program loan (a “PPP loan”), you should begin preparations to maximize your PPP loan forgiveness....more

IRS Notices Give Cafeteria Plan Flexibility for 2020

The IRS has issued Notices 2020-29 and 2020-33 (“Notices”) to give employers with Section 125 cafeteria plans, including health and dependent care spending accounts (FSAs), new flexibility to allow mid-year changes and...more

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