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 These regulations replace regulations that were released in 2016 but were withdrawn by the EEOC in 2019 due to court challenges and confusion.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 ...
Guidance provided by the Consolidated Appropriations Act of 2021 (the “Act”) will temporarily help employers determine if their retirement plans have experienced a “partial termination.” We discussed partial terminations in our recent blog post, and the Act supplements all prior guidance with a bright-line rule for determining when ...
2020 was a year of great uncertainty. Things were constantly changing and almost nothing was guaranteed to happen until it was actually happening. As the year was winding down, there were two things that were certain in my life each week. The first was that the UPS/FedEx truck would be making the truck down my long driveway and the second was I would get ...
Employers want to attract and retain the best talent available. Employers today are cognizant that employees entering the workforce are burdened by mounting student loan debt, and many employers have explored the benefit options available to provide student loan debt relief for their employees. Until the CARES Act, employers were for the most ...
Congress passed, and the President finally signed, the Consolidated Appropriations Act, 2021 (“CAA”). This bill, the fifth longest bill to be passed in the history of Congress, contains over seventy new tax policies, extensions, refinements, and other tax-law clarifications. Within its over 5000 pages is The Taxpayer Certainty and ...
As discussed in our prior post, last July the Department of Labor (“DOL”) and Health and Human Services (“HHS”) released proposed rules regarding grandfathered health plans. Earlier this month, the two agencies issued the final grandfathered plan rules. The final rules follow the proposed rules with no substantive changes.
As a ...
As discussed in our prior blog posts, the PCORI Fee was resurrected by the IRS last year. This past week, the IRS updated the amount of the PCORI Fee for policy years and plan years that end on or after October 1, 2020, and before October 1, 2021. The new amount of the PCORI Fee is $2.66 per covered life. The fee for plan years ending prior to October 1, 2020 ...
Earlier this fall, the Departments of Health and Human Services, Treasury, and Labor (the “Departments”) issued the final rule for “transparency in coverage” requirements for health plans and insurers. The final rule applies to most non-grandfathered group health plans and health insurance issuers will be required to comply with ...
The CARES Act extended the due date for making 2020 contributions to a defined benefit plan to January 1, 2021. In IRS Notice 2020-82, the IRS has now clarified that the 2020 contributions will be treated as timely if made by January 4, 2021, the first business day after January 1, 2021.
In response, the PBGC immediately adjusted its prior guidance ...
Many times, when faced with a possible compliance issue, plan sponsors will debate whether they should call their benefits attorney or not. While attorneys wish this wasn’t the case, it is understood. Fixing compliance issues costs money. No one likes to spend money. An attorney will tell you the risk depends on the circumstances and ask your ...