There are new regulations requiring employers who offer hospital indemnity or other fixed indemnity insurance benefits for plan years starting on or after January 1, 2025, to provide specific notice of the benefit to all...more
Individual Coverage Health Reimbursement Arrangements (ICHRAs) have continued to grow in popularity since their inception in 2019 (see our article here summarizing the 2019 rule establishing ICHRAs). While initially it seemed...more
6/19/2024
/ COBRA ,
Employee Benefits ,
Health Insurance Portability and Accountability Act (HIPAA) ,
ICHRA ,
IRS ,
Medicare ,
Payment Systems ,
PCORI ,
Popular ,
Reporting Requirements ,
Small Business ,
Vendors
A recent string of lawsuits, regulatory guidance, and market trends have dramatically impacted the types of services that enjoy first dollar coverage under high deductible health plan (HDHP) and health savings account (HSA)...more
7/21/2023
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
HDHP ,
Health Care Providers ,
Health Insurance ,
Health Savings Accounts ,
Preventive Health Care ,
Telehealth ,
U.S. Treasury
On January 30th, President Biden announced his intention to end both the COVID-19 national emergency and the COVID-19 public health emergency (together, the “Emergency Declarations”) effective May 11, 2023. The Emergency...more
The Consolidated Appropriations Act, 2021 (CAA) generally requires group health plan sponsors to request and review fee information from their plan service providers who provide brokerage services or consulting. This fee...more
The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) set forth new compensation disclosure requirements that apply to service providers who provide “brokerage services” or “consulting” to group health plans...more
1/14/2022
/ Compensation ,
Consolidated Appropriations Act (CAA) ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Assistance Programs ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Flexible Savings Accounts (FSAs) ,
HRA ,
Pharmacy Benefit Manager (PBM) ,
Third-Party
The American Rescue Plan Act of 2021 (the “ARPA”), which President Biden is expected to sign this week, includes a handful of provisions affecting employee benefit plans and publicly-traded companies’ tax deductions for...more
Last year, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued two notices that extended certain benefit plan deadlines for both employees/plan participants and for plan administrators as a result of...more
The United States Supreme Court recently ruled that certain federal employment protections against sex discrimination extend to employer discrimination based on sexual orientation or gender identity. In light of this ruling,...more
7/15/2020
/ Altitude Express Inc v Zarda ,
Bostock v Clayton County Georgia ,
Civil Rights Act ,
EEOC v RG & GR Harris Funeral Homes ,
Employee Benefits ,
Employer Liability Issues ,
Gender Identity ,
Hiring & Firing ,
LGBTQ ,
SCOTUS ,
Sex Discrimination ,
Sexual Orientation ,
Sexual Orientation Discrimination ,
Title VII ,
Transgender
The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), which was signed by the President on March 27, 2020, includes several provisions affecting employer benefit plans.
Expansion of Withdrawal and Loan...more
In April 2019, the Department of Health and Human Services (HHS) released guidance indicating that a health plan must include the value of financial assistance received from a drug manufacturer (often referred to as a...more
Background. These days, almost all employer-sponsored group health plans require an employee (and any dependents) covered under the plan (each are referred to as a “member”) to pay “out-of-pocket” for covered expenses in the...more
9/10/2019
/ Benefit Plan Sponsors ,
Co-payments ,
Coupons ,
Deductibles ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
Out-of-Pocket Expenses ,
Pharmaceutical Industry ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drugs
Takeaway Message: Except in limited circumstances, current regulatory guidance prohibits an employer from maintaining a health reimbursement arrangement (HRA) that reimburses the cost of premiums for individual health...more
Impact of Tax Reform on Employer-Provided Retirement, Welfare, and Fringe Benefits -
The recently enacted Tax Cuts and Jobs Acts (the “Tax Reform Act”) made significant changes to the Internal Revenue Code. Although there...more
1/8/2018
/ 401k ,
403(b) Plans ,
Affordable Care Act ,
Employee Benefits ,
Fringe Benefits ,
Hardship Distributions ,
Health and Welfare Plans ,
Individual Mandate ,
Individual Retirement Account (IRA) ,
Retirement Plan ,
Roth IRA ,
Tax Cuts and Jobs Act
It’s official. The IRS has finally begun the process of collecting penalties under the Affordable Care Act’s (“ACA”) employer shared responsibility provisions, better known as the “employer mandate.” The IRS has started...more
In December 2016, the Department of Labor issued final regulations under ERISA governing claims procedures for group disability plans, which will become effective January 1, 2018. Generally, these regulations were drafted to...more
3/8/2017
/ Benefit Plan Sponsors ,
Claim Procedures ,
Denial of Benefits ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Impartiality ,
Long Term Disability Insurance ,
Rescission
On December 13, 2016, President Obama signed into law the 21st Century Cures Act, which allows small employers to maintain health reimbursement arrangements (HRAs) for the purpose of reimbursing employees for the cost of...more