Highlighted Posts

Posts from February 2021.

Last Spring, the DOL and IRS issued a Joint Rule that extended a number of participant deadlines under COBRA, HIPAA and ERISA.   Under the Joint Rule, plan sponsors had to extend any of deadline that occurred on or after March 1, 2020 until the 60 days following the end of the National Emergency (referred to as the “Outbreak Period”).  However ...

Last month, we wrote a post on the relief items for FSA participants added by the Consolidated Appropriations Act of 2021 (“CAA”).  The CAA provides a number of relief items for plan participants that employers may choose to implement for their health FSA and dependent care FSA plans.   This relief includes the ability for an employer to offer an ...

In our recent post, we discussed the EEOC’s newest proposed wellness program rules under the ADA and GINA.  As of this week, those proposed rules have been formally withdrawn by the EEOC.  The proposed rules were posted unofficially on the EEOC’s website but were not published in the Federal Register before President Biden took office.

As part of ...

Recently, the EEOC finally released their proposed wellness regulations.  These regulations replace regulations that were released in 2016 but were withdrawn by the EEOC in 2019 due to court challenges and confusion.  These new proposed regulations address wellness programs under both the Americans with Disabilities Act (“ADA”) and the ...

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