News & Analysis as of

U.S. Treasury Employer Liability Issues

Verrill

Prepare for Cooler Weather, Annual Enrollment, and 2025

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Summer is ending and fall is rapidly approaching. For employee benefit professionals with calendar-year health and welfare benefit plans that means preparing for annual enrollment and year-end compliance requirements. This...more

Verrill

IRS Issues Guidance Addressing Matching Contributions on Student Loan Payments

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Section 110 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) permits employers maintaining a 401(k), 403(b), governmental 457(b), or SIMPLE IRA plan to make matching contributions based on qualified student loan payments...more

Bradley Arant Boult Cummings LLP

Inflation Reduction Act Prevailing Wage and Apprenticeship Compliance: Treasury and IRS Issue Final Rule

On June 18, 2024, Treasury and the IRS released the final rule for compliance with the prevailing wage and apprenticeship requirements (PWA requirements) pursuant to the Inflation Reduction Act of 2022 (IRA). This final rule...more

Proskauer - Employee Benefits & Executive...

Transparency in Coverage Rules: When Accurate Estimates for Low‑Utilization Items and Services Are Not Available

Last week, the Departments of Labor, Treasury and Health and Human Services (“the Departments”) issued an FAQ about the final Transparency in Coverage rules (“TiC Rules”). This FAQ addresses compliance with cost‑sharing...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

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McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Spilman Thomas & Battle, PLLC

New Business Reporting Obligations for Employers: Beneficial Ownership Information Under the Corporate Transparency Act

Effective January 1, 2024, most legal entities incorporated, organized, or registered to do business (i.e., LLCs, LLP, PLLC, Inc., Co., etc.) in a state must disclose information relating to its owners, officers, and...more

Bradley Arant Boult Cummings LLP

IRS Announces Transition Period for Roth Catch-Up Contributions

The Internal Revenue Service (IRS) has announced a two-year administrative transition period that delays until 2026 the new rule that catch-up contributions made by certain higher‑income participants in 401(k), 403(b), and...more

Bass, Berry & Sims PLC

New Proposed Mental Health Parity Rules Amid Report of Widespread Failure

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On July 25, the Department of Labor, Department of the Treasury, and Department of Health and Human Services (the Departments) released new Proposed Rules (Proposed Rules) that clarify certain requirements imposed by the...more

McDermott Will & Emery

Treasury, DOL and HHS Issue Landmark Mental Health Parity Proposed Rule

The US Departments of the Treasury, Labor, and Health and Human Services (the Departments) recently issued much-anticipated proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) to better...more

McDermott+

Biden Administration Issues Proposed Reg to Clarify and Enforce Mental Health Parity Requirements

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Another week, a lot more regs! Last week, the US Departments of Health and Human Services, Treasury and Labor (the Departments) released a proposed reg related to mental health parity requirements for health plans. This week,...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Deadline Tolling

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The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April...more

Verrill

The End of the COVID-19 Emergency Declarations Raises Questions, but We’ve Got Answers

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It seems the COVID-19 pandemic is ending in the benefits world the same way it started: in a flurry of new laws, announcements, and notices intended to offer clarity but sowing confusion. To begin, it is important to remember...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: High-Deductible Health Plans and Health Savings Accounts

The Biden administration originally announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our prior article for more information). Although the...more

Bradley Arant Boult Cummings LLP

Departments Issue Guidance on Preventive Services under the ACA Following the Braidwood Decision

In light of the March 30 Braidwood Mgmt. Inc. v. Becerra decision, the Department of Labor, Department of Health and Human Services, and Department of the Treasury (the “departments”) have issued FAQ guidance on how the...more

Bradley Arant Boult Cummings LLP

The End of the COVID-19 Public Health Emergency: Federal Agencies Clarify Coverage Implications for Group Health Plans

With the COVID-19 Public Health Emergency (PHE) set to end on May 11, 2023, the Department of Labor, Department of the Treasury, and Department of Health and Human Services (the “departments”) have published FAQs explaining...more

Faegre Drinker Biddle & Reath LLP

COVID-19 National Emergency Plan Deadline Extensions Set to End This Summer

On January 30, 2023, President Biden announced the Administration’s plan to extend the current declarations of the COVID-19 national emergency and public health emergency (PHE) through May 11, 2023, and end both emergencies...more

Foley Hoag LLP

FTC Proposes Rule Eliminating Non-Compete Agreements Nationwide

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On January 5, 2023, the Federal Trade Commission (“FTC”) proposed a new rule banning non-compete agreements. The 218-page notice of proposed rulemaking details the FTC’s position on the value (or lack thereof) of...more

Bradley Arant Boult Cummings LLP

Noncompete Agreements Under Continued Attack

Employment attorneys and employers are well aware that noncompete and nonsolicitation agreements have been under continued scrutiny by states across the country. While the laws vary from state to state, generally, restrictive...more

Sheppard Mullin Richter & Hampton LLP

Treasury Department Proposes Non-Loan Status for Earned Wage Access

In March, U.S. Department of Treasury issued its annual General Explanations of the Administration’s Revenue Proposals, commonly known as the “Green Book.”  Among other revenue proposals, the Treasury addressed the treatment...more

Bradley Arant Boult Cummings LLP

July 1 Deadline for Health Plan Website Disclosures

The Departments of Labor, Health and Human Services and the Treasury recently issued FAQs About Affordable Care Act Implementation Part 53 (FAQ), which provides additional guidance for non-grandfathered group health plans and...more

Epstein Becker & Green

2022 Mental Health Parity Report to Congress Highlights Increased Enforcement Efforts

On January 25, 2022, the U.S. Department of Labor (“DOL”), Department of Health and Human Services, and Department of the Treasury (collectively, “Departments” or “Regulators”) released their 2022 Annual Report to Congress on...more

McDermott Will & Emery

Agencies Clarify How Employers Can Charge COVID-19 Vaccine Premium Incentives

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On October 4, 2021, the US Departments of Labor, Treasury, and Health and Human Services (the Tri-Agencies) issued guidance regarding the application of the Health Insurance Portability and Accountability Act (HIPAA) wellness...more

Stinson LLP

Agencies Issue COVID-19 Vaccine Incentive Guidance

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On October 4, 2021, the U.S. Department of Health and Human Services, U.S. Department of Labor and U.S. Department of the Treasury jointly issued FAQs relating to COVID-19 vaccine incentives and surcharges. Under the...more

Lewitt Hackman

Executive Order on Deferring Payroll Taxes - Frequently Asked Questions

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On August 8, 2020, the President issued a Presidential Memorandum directing the Secretary of the Treasury to use his authority to defer withholding, deposit, and payment of certain payroll tax obligations (the “Executive...more

Tonkon Torp LLP

What Does The Trump Order On Tax Deferrals Mean For Employers?

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On August 8, 2020, President Trump issued an Executive Order directing Treasury Secretary Mnuchin to allow employers a temporary deferral on withholding, collecting, and remitting certain employment taxes. This is not a tax...more

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