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New Year Brings Extension of California’s Ban on Non-Competes

On Sept. 1, 2023, California enacted a new law (SB 699, to be codified at Cal. Bus. & Prof. Code sec. 16600.5) reiterating its non-compete ban contained in Section 16600 that is effective Jan. 1, 2024.  New Section...more

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

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

Benefits Odds and Ends to Start the Fall

With the passing of summer and the children back in school, it is time to get to work and check on benefit compliance items that you may have missed over the summer. Below is a short summary of a number of developments....more

Class Action Exposure – Rates and Mortality Tables in Your Pension Plan

The phrase “actuarial equivalence” does not roll off anyone’s lips.  But, it may be the key phrase in the next wave of class action potential liability for defined benefit plans.  ...more

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