Plan sponsors, insurers, and third-party administrators should pay close attention to the new guidance to facilitate health plan compliance with complex nonquantitative treatment limitation comparative analyses requirements....more
7/28/2023
/ Benefit Plan Sponsors ,
Centers for Medicare & Medicaid Services (CMS) ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
EBSA ,
Employer Group Health Plans ,
Enforcement ,
Health Insurance ,
Investigations ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
Proposed Rules
The IRS recently issued Notice 2023-43 (Notice) to provide interim guidance on Section 305 of SECURE 2.0 Act of 2022 (SECURE 2.0), which significantly expanded self-correction under the Employee Plans Compliance Resolution...more
The SECURE 2.0 Act of 2022 (SECURE 2.0), the follow-up legislation to the Setting Every Community Up for Retirement Enhancement Act of 2019 (now known as SECURE 1.0) (previously discussed here and here), includes many...more
The Consolidated Appropriations Act 2022 (“CAA 2022”), signed by President Biden on March 15, 2022, reinstated temporary relief for high deductible health plans (“HDHPs”) to provide pre-deductible coverage of telehealth...more
As 2022 begins, retirement plan sponsors and service providers should keep in mind deadlines for required plan changes in 2022. In particular, retirement plan changes under the Setting Every Community Up for Retirement...more
As 2021 winds down, retirement plan sponsors should confirm that their plan documents are amended by December 31, 2021, to comply with certain plan changes:
• Hardship Distributions. 401(k) plans and 403(b) plans must be...more
12/15/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
CARES Act ,
Collective Bargaining Agreements (CBA) ,
Corporate Counsel ,
Deadlines ,
Discretionary Clauses ,
Employee Benefits ,
Hardship Distributions ,
PBGC ,
Retirement Plan ,
SECURE Act ,
Year-End Planning
On July 26, 2021, the Department of Labor (Department) issued frequently asked questions (FAQs) regarding the interim final rule (IFR) on lifetime income illustrations (LIIs) that must be included in participants’ pension...more
Claims-related audio recordings may need to be disclosed to claimants upon request, according to an information letter dated June 14, 2021 (“Information Letter”), issued by the Department of Labor’s (“DOL”) Employee Benefits...more
In our May 2020 client alert, we addressed the possibility that COVID-19 layoffs could inadvertently cause a partial termination of a company’s qualified retirement plan. Recently issued IRS guidance provides that if...more
On June 23, 2020, the Department of Labor, Department of Health and Human Services (HHS), and Department of the Treasury (the Departments) issued new frequently asked questions (FAQs) regarding coverage for COVID-19 testing...more
On June 3, 2020, the Treasury Department issued Notice 2020-42 providing temporary relief from the requirement for a plan representative or notary public to be physically present to witness certain participant elections...more
Employers considering layoffs during this period of economic uncertainty should be aware that extensive layoffs could inadvertently cause a partial termination of their company’s qualified retirement plan. Employers should...more