The American Rescue Plan Act (the Act) included certain temporary COBRA subsidy provisions that allow “Assistance Eligible Individuals” (AEIs) to receive COBRA subsidies from April 1, 2021 to September 30, 2021 (the...more
6/24/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Employee Benefits ,
Employer Group Health Plans ,
Flexible Savings Accounts (FSAs) ,
HRA ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Premium Subsidies ,
Tax Credits
On March 11, 2021, President Biden signed the American Rescue Plan Act (the Act), which includes some notable changes and relief for employers and workers. This legal alert summarizes the key issues relating to the Act’s...more
As the COVID-19 global pandemic continues to impact employers, the IRS has been looking for ways to provide some additional flexibility to employer-sponsored benefit plans. In the past week, the IRS released two notices aimed...more
As employers prepare their workforces for issues related to COVID-19, they should also take steps to ensure that their benefit plans are prepared. The impact of the virus will put a financial and logistical strain on many...more
3/12/2020
/ 401k ,
Benefit Plan Sponsors ,
Coronavirus/COVID-19 ,
Disability Benefits ,
Employee Benefits ,
Employer Group Health Plans ,
Flexible Savings Accounts (FSAs) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HSA ,
PHI ,
Summary of Benefits and Coverage
On December 20, President Trump signed the Further Consolidated Appropriations Act, 2020 (the “Act”), a year-end spending bill that includes key provisions that will affect employer-sponsored benefit plans. This legal alert...more
1/3/2020
/ Affordable Care Act ,
Appropriations Bill ,
Cadillac Tax ,
Employer Group Health Plans ,
Federal Funding ,
Health Insurance ,
Medical Devices ,
Medical Leave ,
Paid Family Leave Law ,
Paid Leave ,
PCORI ,
Repeal ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders
On November 15, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Agencies”) issued a proposed "Transparency in Coverage" rule that would require most...more
12/4/2019
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Corporate Counsel ,
Cost-Sharing ,
Employer Group Health Plans ,
Executive Orders ,
Health Care Providers ,
Proposed Rules ,
Regulatory Agencies ,
Self-Insured Health Plans ,
TPAs ,
Transparency
On December 14, 2018, a Texas District Court ruled that the Affordable Care Act’s (ACA) requirement that certain individuals maintain a minimum level of health coverage, often referred to as the “Individual Mandate,” is...more
1/7/2019
/ Affordable Care Act ,
Appeals ,
Constitutional Challenges ,
Department of Homeland Security (DHS) ,
Employer Group Health Plans ,
Health Insurance ,
Individual Mandate ,
Internal Revenue Code (IRC) ,
Stays ,
Tax Cuts and Jobs Act ,
Trump Administration
On June 21, 2018, the Department of Labor (DOL) issued final regulations establishing alternative criteria under section 3(5) of the Employee Retirement Income Security Act of 1974 (ERISA) for forming single-employer...more
The stopgap government funding bill passed by Congress on January 22 included a two-year delay of the Affordable Care Act’s excise tax on high cost employer-sponsored health coverage, commonly referred to as the “Cadillac...more
This ACA Brief is the fifth in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that affect large employer-sponsored plans.
On May 4, 2017, the US House...more
This ACA Brief is the fourth in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that affect large employer-sponsored plans.
On March 6, 2017, the U.S....more
This ACA Brief is the third in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that impact large employer-sponsored plans.
As detailed in Sutherland’s...more
This ACA Brief is the first in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that impact large employer-sponsored plans.
On January 12, the U.S....more
A Wisconsin federal district court dismissed (with prejudice) a complaint by the Equal Employment Opportunity Commission (EEOC) that a company’s wellness program violated the Americans with Disabilities Act (ADA). The EEOC...more
On February 23, the Internal Revenue Service (IRS) issued Notice 2015-16 (Notice), which describes several possible approaches for implementing the excise tax on high-cost employer-sponsored health care plans (also known as...more
On December 30, the Departments of Treasury, Labor, and Health and Human Services published a joint notice of proposed rulemaking modifying the Summary of Benefits and Coverage (SBC) final regulations issued in 2012. In...more
The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. The updated plans are reflected in the attached chart.
...more
The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more