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Managing Welfare Plan Risk: The Fiduciary Committee

Fiduciary committees have long been established in connection with retirement plans to manage the investment, legal compliance, and operational risks that can arise under the Employee Retirement Income Security Act of 1974,...more

COVID-19 Public Health and National Emergencies to End May 11—or Earlier

With the COVID-19 public health emergency and the presidential declaration of national emergency intended to end on May 11 and the US government recently issuing guidance on unwinding these emergency declarations, this...more

Health and Welfare Plan Year-End Reminders

Permissible Flexibility under Code Section 125 Pursuant to IRS Notice 2021-15 Notice 2021-15 offered plan sponsors the flexibility to adopt any of the following options despite the longstanding rules under Section 125 of the...more

IRS Provides Second Round of FAQs on COBRA Subsidies

As we get closer to the September 30 expiration date of the COBRA premium subsidy provided under the American Rescue Plan Act (ARPA), the IRS has issued a second set of FAQs in Notice 2021-46 (Notice) to supplement its prior...more

IRS Issues Guidance Regarding American Rescue Plan Act COBRA Subsidy

The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the...more

DOL Issues ARPA COBRA Subsidy Model Notices and FAQs

As we described in our March 15, 2021 LawFlash, the American Rescue Plan Act of 2021 (ARPA) includes a 100% COBRA premium subsidy for any employee or dependent who is a COBRA qualified beneficiary ...more

American Rescue Plan’s Health and Welfare Benefit Provisions: COBRA and DCFSA Action Items

The American Rescue Plan Act of 2021 includes a COBRA premium subsidy and increases the dependent care flexible spending account (DCFSA) limits. While the availability of the COBRA premium subsidy is a requirement, the...more

Initial Key Takeaways from the American Rescue Plan Act of 2021

President Joseph R. Biden signed the American Rescue Plan Act of 2021 on March 11, which provides $1.9 trillion in relief funds across a broad spectrum of categories, including additional support for vaccine distribution,...more

Suspended Deadlines Under ERISA, Part Two: Sound the Alarm!

At the 11th hour, the US Department of Labor’s Employee Benefits Security Administration (EBSA), with coordination and review by the Internal Revenue Service and the Department of Health and Human Services (collectively, the...more

Suspended Deadlines Under ERISA: Is It Time to Restart the Clock?

As we described in our LawFlash from last spring, the US Department of Labor’s Employee Benefits Security Administration (EBSA) and the Internal Revenue Service (IRS) (collectively, the Agencies) issued EBSA Notice 2020-01...more

COVID-19: Agencies Issue Disaster Relief for Welfare Plans

The US Department of Labor’s Employee Benefits Security Administration (DOL) and the Internal Revenue Service (IRS) issued guidance last week providing deadline and other relief affecting welfare plans and their sponsors and...more

Group Health Plans: Year-End Action Items and Upcoming Changes

Group health plan sponsors turn their attention to completing 2013 tasks, implementing upcoming 2014 changes, preparing for the ACA Shared Responsibility requirement in 2015, and documenting recent extensive plan changes....more

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