Benefits - General

In response to comments from various organizations representing employers, plans, recordkeepers, and other service providers, the U.S. Department of Labor (“DOL”) published a rule revising the timeframe for administrators to provide certain expense and investment annual disclosures to individuals pa

On March 16, 2015, the U.S. Departments of Labor, Health and Human Services, and Treasury finalized regulations that would treat certain limited health coverage that wraps around eligible individual health insurance or multi-state plan coverage offered by the U.S. Office of Personnel Management (OPM

Sponsors of large, self-funded health plans struggling with the new Health Plan ID (HPID) requirement received a last-minute reprieve from the Centers for Medicare & Medicaid Services (CMS). On Friday, the CMS announced an enforcement “delay” with respect to the health plan enumeration and HPID regu

The Centers for Medicare and Medicaid Services (CMS) has revised its Health Plan ID (HPID) FAQs to provide clearer guidance for employers who wrap multiple self-funded benefit programs into a single ERISA plan for purposes of the annual Form 5500 filing. In what was previously unclear, the updated g

On the heels of the Supreme Court’s decision in Heimeshoff v. Hartford Life & Acc. Ins. Co, a federal district court in New York has held in Halpern v. Blue Cross/Blue Shield of Western New York, 12-CV-407S (W.D.N.Y., Sept. 4, 2014) that a group health benefit plan’s shorter one-year limitations per

President Obama recently signed into law the Highway and Transportation Funding Act of 2014 (“HATFA”), which extends the pension smoothing provisions included in the 2012 Moving Ahead for Progress Act for the 21st Century (“MAP-21”). MAP-21 amended Section 430 of the Internal Revenue Code (the “Code

The Department of Labor (DOL) recently issued a new Field Assistance Bulletin (FAB 2014-01) that provides guidance regarding the steps a plan administrator should take to fulfill his or her fiduciary duty to locate and distribute account balances to missing participants in terminated defined contrib

Executive Summary: On July 22, 2014, the U.S. Department of Labor (DOL) issued its annual memorandum announcing that, pursuant to 29 C.F.R. Section 4.52, the prevailing hourly health and welfare fringe benefit rates under the McNamara-O'Hara Service Contract Act (SCA) were increasing from $3.81 per

Various federal agencies, including the DOL’s Employee Benefits Security Administration (EBSA), have issued a proposal to amend regulations governing excepted benefits to permit health plan sponsors to provide coverage for limited scope vision, dental, wraparound, and employee assistance programs (E

Year-End AmendmentsThe month of December is a bit different in 2013. Typically, we mark this time scrambling to amend 401(k), profit sharing, and money purchase plans in order to maintain their tax-qualified status. This year -- there are no required year-end amendments for this type of plan.

The Internal Revenue Service has released a detailed list of pension plan and other retirement-related contribution limitations for Tax Year 2014 that were triggered by an increase in the cost-of-living index. As stated in the release, “[s]ome pension limitations such as those governing 401(k) plans

The Department of Labor’s Employee Benefits Security Administration (EBSA) has issued its 16th set of Frequently Asked Questions (FAQs) on the Affordable Care Act’s (ACA) implementation. The latest guidance addresses questions on the notice of coverage options available through the future health exc

The Kaiser Family Foundation and the Health Research & Educational Trust (Kaiser/HRET) have released their annual survey of employer-sponsored health benefits. In the survey, Kaiser/HRET analyzes the responses provided by 2,067 public and private employers with three or more employees during the fir

Executive Summary: The Department of Labor ("DOL") recently released a series of final rules affecting health benefits provided through multiple employer welfare arrangements ("MEWAs"). Notably, the 2012 Form M-1 filing deadline has been extended to May 1. In addition, new guidance implementing port

Executive Summary: As most everyone knows by now, Congress adopted, and President Obama signed, legislation – the American Taxpayer Relief Act (the "Act") – that resolves many elements of the so-called "fiscal cliff," i.e., the various tax increases and expiration of tax breaks, along with spending

Executive Summary: In Announcements 2012-45 and 2012-46, the IRS has temporarily eased the eligibility requirements for employers to participate in the employment-tax Voluntary Classification Settlement Program ("VCSP") that was begun last year. (See our Legal Alert dated 9/27/2011.) Specifically, e

Executive Summary: In addition to the other various employee benefit plan relief provided as a result of Hurricane Sandy, on November 16 the Internal Revenue Service announced, in Announcement 2012-44, that certain individual account plans, including Section 401(k) plans, Section 403(b) tax-sheltere

On October 18, 2012, the Internal Revenue Service announced cost of living adjustments affecting various limitations applicable to pension and other retirement plans (IR 2012-77). Many of the limitations remain unchanged because they are indexed in $1000 or $5000 increments, but several will change