Making Effective Use of the Claims/Disputes Process
The US Department of Labor (DOL) issued Information Letter 06-14-2021 last month to the attorney of a plan participant who requested a copy of an audio recording and transcript of a phone conversation he or she had with the...more
The Employee Benefits Security Administration issued Information Letter 06-14-2021 stating that 29 C.F.R. § 2560.503-1 requires plan fiduciaries to disclose, on request, recordings and/or transcripts of phone calls between...more
- Create a Plan Document... - Do not rely solely on special acts, ordinances, or collective bargaining agreements... - Reflect collectively bargained provisions... - Update contemporaneously to reflect changes in...more
As the end of the calendar year approaches, sponsors of qualified retirement plans should consider whether their plan documents require updates to comply with important legal changes and deadlines. Below is a summary of some...more
On July 12, 2018, a previous alert entitled “Bullet Proofing Your Claims Process” discussed lessons learned from a recent 5th Circuit decision in White v. Life Insurance Company of North America, (5th Cir. June 13, 2018,...more
New federal rules apply for processing disability claims made under employee benefit and executive deferred compensation plans after April 1, 2018. Employers sponsoring retirement plans, disability plans, or nonqualified...more
After a three-month delay, the Department of Labor’s new regulations governing claims procedures for disability benefits under ERISA plans will become effective on April 1, 2018. The delay was implemented to provide an...more
On April 2, 2018, significant changes to ERISA’s disability claims procedures will take effect. These new rules will require all ERISA-covered plans which provide disability benefits to make significant modifications to the...more
The Department of Labor’s new regulations governing disability claims and appeals published on December 19, 2016 will go into effect on April 1, 2018, as announced by the DOL on January 5, 2018. ...more
In recent talks and appearances, representatives of the U.S. Department of Labor have issued a warning about new areas of focus of DOL audits and enforcement actions. While there are a number of different enforcement...more
The U.S. Court of Appeals for the Second Circuit’s holding in Kirkendall v. Halliburton, Inc. reaffirms that a benefit plan’s claims procedures must be drafted clearly and in language to be understood by a reasonable...more