PODCAST: Williams Mullen's Benefits Companion - Can Employers Impose a Health Insurance Surcharge on Plan Participants Not Vaccinated for COVID-19?
The IRS recently issued Notice 2022-27, providing a six-month extension of the temporary relief from the physical presence requirement for certain plan elections (including spousal consents) required to be witnessed by a plan...more
We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more
Employers that are considering imposing health plan premium surcharges to encourage their employees to get vaccinated have clearer guidance on how to do so without running afoul of the nondiscrimination rules under the Health...more
On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt explores compliance considerations for employers who are considering imposing a health insurance surcharge on plan participants who are not...more
As we previously reported in 2020, the IRS granted temporary relief from the physical presence requirement under regulations governing participant elections and spousal consents for certain retirement plans. Generally, those...more
Certain elections made by participants and spouses under retirement plans must be signed “in the physical presence of a plan representative or a notary public.” The IRS provided relief from this physical presence requirement...more
In EBSA Disaster Relief Notice 2021-01, the Department of Labor (DOL) has issued a critical interpretation of prior guidance that extended certain deadlines for employee benefit plans, participants, and beneficiaries due to...more
In our April 2020 post, we detailed how employee layoffs can cause a qualified retirement plan to undergo a “partial termination,” resulting in required 100% vesting of the affected employees’ benefits. As 2020 drew to a...more
Kiplinger conducted a poll that showed that plan participants did raid their retirement plan accounts because of COVID. ...more
The Consolidated Appropriations Act, 2021, enacted on December 27, 2020 (the CAA), includes limited relief pertaining to the partial termination of a qualified retirement plan that may have been inadvertently triggered by...more
On July 23, 2020, the Secretary of the Department of Health and Human Services ("HHS") issued another 90-day extension regarding free COVID-19 testing. The free COVID-19 testing requirement was set to expire on July 25, but...more
COBRA: an acronym that strikes fear (and understandable confusion) into the hearts of many employers. If you have 20 or more employees, you are subject to the often equivocal requirements of the Consolidated Omnibus Budget...more
Plan participants and their beneficiaries may now have extra time to exercise some of their rights under the employee benefit plans in which they participate. ...more
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). Among its many and varied forms of relief, the CARES Act provides temporary relief for both plan...more
As a result of the ongoing COVID-19 pandemic, we are observing all sorts of never-before-seen changes in the fully-insured group health plan space. Many insurers are liberally waiving their normal rules to accommodate the...more