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Additional Guidance on Fee Disclosures

On May 7, 2012, the DOL published Field Assistance Bulletin 2012-02 (the “FAB”) providing additional guidance and clarification for employers and other plan fiduciaries regarding the participant-level fee disclosure regulation (29 CFR 2550.404a-5) applicable to participant-directed individual account plans (e.g., 401(k) and 403(b) plans; see our earlier article regarding these regulations).  The FAB is also relevant to covered service … Continue reading Additional Guidance on Fee Disclosures
May 22, 2012

How Should Employers Handle Health Insurance Rebates?

  Some employers that sponsor insured group health plans will receive rebates this year from insurers due to the medical loss ratio limits imposed on insurers under the Patient Protection and Affordable Care Act of 2010 (as amended by the Health Care and Education Reconciliation Act of 2010, together “Health Care Reform”). Under applicable Health Care … Continue reading How Should Employers Handle Health Insurance Rebates?
May 16, 2012

Health Care Reform Update: DOL Provides Guidance on Summary of Benefits and Coverage Requirement

The US Department of Labor (“DOL”) has released frequently asked questions (“FAQs”) regarding implementation of the federal health care reform law’s summary of benefits and coverage requirement. (This set of FAQs is Part VIII in the general series about implementation of the law.) See our earlier blog post regarding the summary of benefits and coverage regulations that were … Continue reading Health Care Reform Update: DOL Provides Guidance on Summary of Benefits and Coverage Requirement
March 21, 2012

Funding Relief May be on the Way for Employers Sponsoring Defined Benefit Plans

Welcome relief may be in store for employers that are facing significant minimum funding obligations to their defined benefit retirement plans. The Senate, on March 14, 2012, passed with strong bipartisan support a surface transportation reauthorization bill called the “Moving Ahead for Progress in the 21st Century (MAP-21) Act” (S. 1813), which includes a pension funding … Continue reading Funding Relief May be on the Way for Employers Sponsoring Defined Benefit Plans
March 19, 2012

Group Health Plan Summary of Benefits and Coverage Due By Next Open Enrollment

  The agencies primarily responsible for enforcing the Patient Protection and Affordable Care Act of 2010 issued 150 pages of final regulations implementing the mandate that group health plans and insurers provide a four-page summary of benefits and coverage to individuals who enroll in health plans. Under the regulations issued February 9, 2012, plan administrators and … Continue reading Group Health Plan Summary of Benefits and Coverage Due By Next Open Enrollment
February 10, 2012

Fee Disclosures to Participants in 401(k) and 403(b) Plans) Due By August 30, 2012

Under  Department of Labor Regulations, plan administrators of individual account plans such as 401(k) plans and most 403(b) plans must provide all participants who are eligible to direct investments in the plan with certain investment and fee information (see http://www.dol.gov/ebsa/newsroom/fsparticipantfeerule.html for more information).  The plan administrator is the employer sponsoring the plan unless the employer has designated another plan … Continue reading Fee Disclosures to Participants in 401(k) and 403(b) Plans) Due By August 30, 2012
February 9, 2012

Additional IRS Guidance on W-2 Reporting of Health Care Costs

The Internal Revenue Service (“IRS”) has  amended its guidance to employers on how to report the cost of group health coverage. Notice 2012-9 addresses, among other things, cost determinations for employee assistance programs, wellness programs, and health reimbursement arrangements.  Internal Revenue Code section 6051(a)(14), enacted as part of the Patient Protection and Affordable Care Act of … Continue reading Additional IRS Guidance on W-2 Reporting of Health Care Costs
January 22, 2012

San Francisco Amends Its Health Care Ordinance – Changes Effective January 2012

San Francisco’s Health Care Security Ordinance has been amended to require more of certain employers with workers in the City and County of San Francisco. The amendments will take effect January 1, 2012. Employers, particularly those using a health reimbursement account plan (HRA) or a health savings account (HSA) plan to comply with the Ordinance, … Continue reading San Francisco Amends Its Health Care Ordinance – Changes Effective January 2012
December 8, 2011

IRS Voluntary Classification Settlement Program – Watch Your Step!

The Internal Revenue Service has announced its Voluntary Classification Settlement Program (“VCSP”) offering relief to certain employers from unpaid employment taxes, penalties and interest that may result from misclassification of workers.  The IRS’s September 21, 2011, Announcement 2011-64 and “Frequently Asked Questions” (published on September 30) explains that the VCSP allows employers to correct misclassification … Continue reading IRS Voluntary Classification Settlement Program – Watch Your Step!
October 10, 2011

Eleventh Circuit Decides Health Care Reform Individual Mandate Is Unconstitutional

The individual mandate provision of the 2010 health care reform law is unconstitutional, the U.S. Court of Appeals for the Eleventh Circuit decided in Florida v. HHS on August 12th. The Sixth Circuit previously held in Thomas More Law Center v. Obama that the individual mandate is constitutional. Therefore, the Eleventh Circuit decision creates a circuit split, … Continue reading Eleventh Circuit Decides Health Care Reform Individual Mandate Is Unconstitutional
August 15, 2011

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