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It’s Official - Implementation of Final Rule on Disability Claims Procedures Formally Delayed

On November 24, 2017, the Department of Labor (“DOL”) Employee Benefits Security Administration (“EBSA”) formally delayed the applicability date of previously issued final regulations imposing new claims procedures to...more

The Department of Labor Confirms June 9th as the Effective Date of the Fiduciary Rule: What Employers Need to Know Now

On May 22, 2017, Secretary of Labor Jim Acosta announced that, after having been delayed 60 days, the Department of Labor’s (“DOL”) Conflict of Interest Rule (“Fiduciary Rule”) will largely apply on June 9, 2017. At that...more

New Cash Balance Retirement Plan Guidance

On April 7, 2017, the IRS issued a memorandum relating to cash balance retirement plans. A cash balance plan is a defined benefit pension plan which looks like a defined contribution plan because participants have individual...more

Small Employer Standalone HRA Allowed by New Law

Effective January 1, 2017, small employers with fewer than 50 full-time employees will be allowed to offer employees a standalone health reimbursement account (“HRA”) without being subject to an excise tax under a law passed...more

IRS Relaxes Section 83(b) Filing Requirements

A taxpayer who makes a Section 83(b) election to accelerate the income taxation date of certain transferred property is no longer required to file a copy of the Section 83(b) election with his or her tax return for the year...more

Refresher Course on Affordable Care Act Individual and Employer Penalties For Not Having Health Insurance

Even though penalties for failure to comply with Affordable Care Act (ACA) coverage requirements have been in force since January 1, 2014 for employers with 100 or more full-time equivalent employees and January 1, 2015 for...more

The IRS Overhaul of the Determination Letter Process: What Plan Sponsors Need to Know

Last summer, the Internal Revenue Service (IRS) announced that its periodic review of individually designed retirement plans to determine the plans’ qualified status will end effective January 31, 2017. In January 2016, the...more

Affordable Care Act Update – Some Questions Answered, Some Relief Granted

Within the last week, there has been a flurry of activity from both Congress and the Internal Revenue Service (“IRS”) with respect to the Affordable Care Act (“ACA”). This client alert first reviews the delayed effective date...more

Employer Paid Individual Health Insurance Policies Create the Potential for Significant Penalties, But Limited Relief Is Available

Despite guidance from the Internal Revenue Service (“IRS”), the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) indicating the prohibition of the practice under the Affordable Care Act...more

U.S. Supreme Court Decision on ERISA Fiduciary Duty Statute of Limitations Case Provides Broad Principle But Little Practical...

Last week the U.S. Supreme Court issued its opinion in Tibble v. Edison International, a highly anticipated case involving whether ERISA’s six year statute of limitations for breach of fiduciary duty claims prevented a claim...more

Deadline Approaching to Secure Health Plan Identifier (“HPID”)

Certain group health plans are required to obtain a 10-digit Health Plan Identifier ("HPID") from the Center for Medicare and Medicaid Services ("CMS") by November 5, 2014. Currently various users of the health care system...more

10/29/2014  /  CMS , FSA , Healthcare , HIPAA , HPID , HSA , Medicaid , Medicare

ACA, HIPAA, COBRA and HSA Penalties: What Do They Mean?

What do all of these acronyms stand for and why do employers and human resource professionals care? These acronyms stand for statutory requirements which apply to employer-provided health plans and stiff penalties can apply...more

IRS Provides Much Needed Clarification for Employee Benefit Plans After U.S. Supreme Court Case Strikes Down Defense of Marriage...

On August 29, 2013, IRS issued Revenue Ruling 2013-17 which clarified that for federal income tax purposes, the marital status of a same-sex couple is based on the state law or foreign law (e.g. Canada) where the marriage was...more

New Notice Requirements To Employees Regarding Health Insurance Exchanges And COBRA

All employers who employ one or more employees and are subject to the Fair Labor Standards Act (“FLSA”) must provide a new notice to employees no later than October 1, 2013 regarding the availability of health coverage under...more

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