We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more
10/12/2023
/ Abortion ,
Affordable Care Act ,
Birth Control ,
Cafeteria Plans ,
CARES Act ,
Children's Health Insurance Program (CHIP) ,
Civil Rights Act ,
COBRA ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Cost-of-Living Adjustment (COLA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Dobbs v. Jackson Women’s Health Organization ,
Drug Pricing ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Families First Coronavirus Response Act (FFCRA) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Health Plan Sponsors ,
IRS ,
MHPAEA ,
Non-Discrimination Rules ,
NQTLs ,
Out of Network Provider ,
Penalties ,
Pharmacy Benefit Manager (PBM) ,
Popular ,
Recordkeeping Requirements ,
Reporting Requirements ,
Reproductive Healthcare Issues ,
Student Loans ,
Surprise Medical Bills ,
Title VII ,
Transparency ,
Travel Time ,
Wellness Programs
We have reported previously on the importance of understanding the coverage and reporting rules of the Affordable Care Act. In particular, Code Section 4980H imposes penalties on large employers for failure to offer minimum...more
If you need help determining whether you are an “applicable large employer” subject to these rules or estimating the extent of potential penalty exposure, our Employer Shared Responsibility Penalty Checklist for Employers may...more
Since it was enacted in 2010, Section 1557 of the Affordable Care Act (“Section 1557”) has prohibited discrimination in covered health programs and activities on the basis of race, color, national origin, age, disability, or...more
We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more
11/11/2021
/ Affordable Care Act ,
Benefit Plan Sponsors ,
CARES Act ,
COBRA ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Health and Welfare Plans ,
Plan Participants ,
Retirement ,
Retirement Plan ,
Retirement Plan Providers
Despite myriad legal challenges, the Affordable Care Act (“ACA”) remains the law of the land. We previously reported on the Supreme Court’s latest validation of the law in our SW Benefits Update, “Three Strikes You’re Out –...more
As in prior years, the IRS has provided relief for employers preparing to comply with the Affordable Care Act’s (“ACA”) information reporting requirements in early 2021 for the 2020 calendar year. In particular, Notice...more
We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more
9/28/2020
/ Affordable Care Act ,
Anti-Discrimination Policies ,
Benefit Plan Sponsors ,
COBRA ,
Compensation & Benefits ,
Coronavirus/COVID-19 ,
Cost-of-Living Adjustment (COLA) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Executive Compensation ,
Families First Coronavirus Response Act (FFCRA) ,
HDHP ,
Health Insurance Portability and Accountability Act (HIPAA) ,
IRS ,
MHPAEA ,
Retirement Plan ,
Trump Administration ,
Year-End Tax Planning
On June 15, 2020, the United States Supreme Court issued a landmark opinion in Bostock v. Clayton County Georgia. At issue in Bostock was whether an employer could fire an employee for being gay or transgender without...more
6/24/2020
/ Affordable Care Act ,
Bostock v Clayton County Georgia ,
Civil Rights Act ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employer Liability Issues ,
Fringe Benefits ,
Hiring & Firing ,
LGBTQ ,
SCOTUS ,
Section 1557 ,
Sex Discrimination ,
Sexual Orientation Discrimination ,
Title VII ,
Transgender
The IRS provided welcome news to employers preparing to comply with the Affordable Care Act’s (“ACA”) information reporting requirements in early 2020 for the 2019 calendar year. In particular, Notice 2019-63 (the “Notice”)...more
As 2019 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health...more
10/18/2019
/ Affordable Care Act ,
Americans with Disabilities Act (ADA) ,
Benefit Plan Sponsors ,
Civil Rights Act ,
COBRA ,
Cost-of-Living Adjustment (COLA) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Liability Issues ,
Equal Employment Opportunity Commission (EEOC) ,
Federal Contractors ,
HDHP ,
Health and Welfare Plans ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Individual Mandate ,
IRS ,
Minimum Essential Coverage ,
OFCCP ,
Retirement Plan ,
Shared Responsibility Rule ,
Title VII ,
TPAs ,
Wage and Hour
In 2016, the Department of Health and Human Services (“HHS”) Office of Civil Rights issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act (“Section 1557”), which prohibit the...more
6/11/2019
/ Affordable Care Act ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employer Group Health Plans ,
Equal Employment Opportunity Commission (EEOC) ,
Mental Health ,
OCR ,
Proposed Regulation ,
Section 1557 ,
Title VII ,
Transgender ,
Trump Administration
On October 29, 2018, proposed regulations were published in the Federal Register that would permit employers to offer two new types of health reimbursement arrangements (“HRAs”) that align with the requirements of the...more
The IRS delivered welcome news to employers preparing to meet the Affordable Care Act’s (“ACA”) information reporting deadlines in early 2019 for the 2018 calendar year. In Notice 2018-94 (the “Notice”), the IRS extended the...more
Late last year, the Internal Revenue Service (the “Service”) began enforcing penalties with respect to failures to comply with the employer shared responsibility provisions of Section 4980H of the Internal Revenue Code. In...more
As we recently reported in our “2017 End of the Year Plan Sponsor To Do List,” applicable large employers must continue to submit to the IRS and to employees information regarding offers of health coverage made to full-time...more
On December 22, 2017, the Tax Cuts and Jobs Act (“the Act”) was signed into law, and it has various implications for employers who sponsor employee benefit plans. This newsletter focuses on the provisions in the Act that...more
1/30/2018
/ Affordable Care Act ,
Compensation & Benefits ,
Family and Medical Leave Act (FMLA) ,
Fringe Benefits ,
Health and Welfare Plans ,
Individual Mandate ,
Minimum Essential Coverage ,
New Legislation ,
Paid Leave ,
Popular ,
Reimbursements ,
Tax Cuts and Jobs Act
As 2017 comes to an end, we are pleased to present you with our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are publishing our “To Do” Lists in four separate Employee Benefits Updates. Part 1 covered...more
11/21/2017
/ 401k ,
Affordable Care Act ,
Automatic Enrollment ,
Benefit Plan Sponsors ,
Best Interest Contract Exemptions ,
Department of Labor (DOL) ,
Determination Letter ,
Disability Benefits ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Fiduciary Rule ,
Filing Requirements ,
Form 5500 ,
Hardship Distributions ,
IRS ,
Natural Disasters ,
Proposed Rules ,
Qualified Retirement Plans ,
Retirement Plan ,
Safe Harbors ,
Summary Plan Description
As 2017 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are presenting our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 will cover...more
10/18/2017
/ 21st Century Cures Act ,
AARP ,
Affordable Care Act ,
Breach Notification Rule ,
Cadillac Tax ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Rights Act ,
Cloud Service Providers (CSPs) ,
COBRA ,
Code Sections 4980H ,
Cost-of-Living Adjustment (COLA) ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Disability Benefits ,
Electronic Protected Health Information (ePHI) ,
Employee Assistance Programs ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employment Discrimination ,
Equal Employment Opportunity Commission (EEOC) ,
Executive Orders ,
Federal Contractors ,
Federal Poverty Line ,
Filing Deadlines ,
Form 5500 ,
Form 720 ,
Full-Time Employees ,
Health Insurance Exchanges ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare Reform ,
Information Letters ,
IRS ,
MHPAEA ,
Minimum Essential Coverage ,
Non-Grandfathered Health Plans ,
Open Enrollment ,
PCORI ,
Preventive Health Care ,
Qualified Small Employer Health Reimbursement Plan (QSEHRAs) ,
Religious Exemption ,
SBC ,
Section 1557 ,
Section 6055 ,
Section 6056 ,
Shared Responsibility Rule ,
Tax Credits ,
Tax Penalties ,
Telemedicine ,
Title VII ,
Trump Administration ,
Wellness Programs
In a series of tweets published on July 26, 2017, President Trump announced a ban on transgender service in the armed forces. In the wake of this reversal of government policy, employers may question the current state of...more
8/12/2017
/ Affordable Care Act ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employer Group Health Plans ,
Equal Employment Opportunity Commission (EEOC) ,
Non-Discrimination Rules ,
Popular ,
Preliminary Injunctions ,
Section 1557 ,
Title VII ,
Transgender ,
Trump Administration ,
Twitter
As efforts to reform the Affordable Care Act (the “ACA”) stall in Congress, a recent government report suggests that the Internal Revenue Service is preparing to identify and collect employer shared responsibility penalties....more
The IRS delivered welcome news to employers gearing up to meet the Affordable Care Act’s (“ACA”) information reporting deadlines for the 2016 calendar year. In Notice 2016-70, the IRS extended the deadline to furnish Forms...more
In recent months, we have written a fair amount about providing transgender benefits in light of the nondiscrimination provisions of the Affordable Care Act. Our blogs of March 30, 2016 and June 22, 2016 highlight the key...more
On April 6, 2016, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued an updated Summary of Benefits and Coverage (“SBC”) template. The latest template represents an effort by the...more
On May 18, 2016, the Department of Health and Human Services (“HHS”) issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act. As we discussed in our March 30, 2016 blog, the rule...more