On October 17, 2024, the IRS issued two Notices: one regarding preventive care services that an HSA-compatible high deductible health plan (“HDHP”) can cover on a pre-deductible basis and another allowing the cost of condoms...more
On October 22, 2024, the IRS issued Rev. Proc. 2024-40, which announces the 2025 indexed limits for certain health and welfare benefits. This is in addition to the limits that the IRS announced on May 9, 2024 in Rev. Proc....more
The Department of Labor (“DOL”) recently released a final regulation (the “Fiduciary Rule”) redefining “investment advice” under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and section 4975 of...more
On April 16, 2024, the IRS issued Fact Sheet 2024-13, which includes FAQs addressing the tax treatment of employer-provided work-life referral services. The FAQs generally provide that the value of these services can be...more
On November 9, 2023, the IRS issued Rev. Proc. 2023-34, which announces the 2024 indexed limits for certain health and welfare benefits. This is in addition to the limits that the IRS announced on May 16, 2023 in Rev. Proc....more
The Department of Labor (“DOL”) has sent a new, proposed fiduciary rule to the Office and Management and Budget (“OMB”) for review. The text of the proposal is not yet public. OMB must first conduct an interagency review...more
On July 7, the Departments of Labor, Treasury, and Health and Human Services published a proposed rule (“Proposed Rule”) regarding, among other things, the requirements for fixed and hospital indemnity insurance to be...more
On June 23, 2023, the IRS issued Notice 2023-37 (the “2023 Notice”) regarding COVID-19-related coverage for HSA-compatible high-deductible health plans (“HDHPs”) and preventive care for HDHP purposes in light of the district...more
On June 8, 2023, the IRS released Chief Counsel Advice 202323006 (the “CCA”) addressing the tax treatment of wellness indemnity payments made by employer-funded fixed indemnity insurance policies. The CCA generally provides...more
On April 28, 2023, the Internal Revenue Service (“IRS”) Office of Chief Counsel issued a Chief Counsel Advice (“CCA”) explaining the requirements for claim substantiation for health and dependent care flexible spending...more
Over the years, many plan sponsors have accumulated surplus assets in their pension and welfare benefit programs for various reasons. Typically, surplus assets have been generated in these mature programs through some...more
On June 16, 2022 Groom will be hosting a webinar on the impact of state abortion restrictions on employers, insurers, and self-insured plans. Over the past year, numerous states have enacted new abortion restrictions, and we...more
On March 28, the Biden Administration submitted its Fiscal Year 2023 budget proposals reflecting its budget and tax policy priorities, which could surface when Congress resumes work on budget reconciliation. While it is...more
Today, President Biden signed into law the Consolidated Appropriations Act, 2022 (“CAA 2022”), which, among other things, temporarily renews certain relief to individuals to have access to telehealth coverage and other remote...more
On December 2, 2021, President Biden announced new actions to combat COVID-19, given the emergence of the new Omicron variant. As part of his nine-point plan, the President included a directive that “the more than 150...more
Illinois recently enacted the Consumer Coverage Disclosure Act (the “CCDA”), which requires that Illinois employers provide a disclosure to employees regarding how the employer’s group health plan compares with the essential...more
On December 2, 2021, President Biden announced new actions to combat COVID-19, given the emergence of the new Omicron variant. As part of his nine-point plan, the President included a directive that “the more than 150...more
On October 6, 2021, the IRS released Notice 2021-58 (the “Notice”), which provides yet another round of guidance on the application of extended deadlines for COBRA elections and payments due to COVID-19. This guidance expands...more
With rising rates of COVID-19 cases in the past few months, employers have been increasingly interested in exploring incentives designed to increase COVID-19 vaccination rates among employees. One idea that has been gaining...more
On September 15, the House Ways and Means and Energy and Commerce Committees advanced components of the Democrats’ $3.5 trillion budget reconciliation package (“Budget Legislation” or “the Legislation”). The Legislation...more
On July 26, 2021, the IRS released Notice 2021-46 (the “Notice”), which provides new guidance on the 100% COBRA premium subsidies (the “Subsidies”) and the related tax credit under the American Rescue Plan Act of 2021 (March...more
Since the American Rescue Plan Act (“ARPA”) was enacted in March 2021, employers and insurers have been diligently familiarizing themselves with the rules for administering the temporary 100% COBRA premium subsidy established...more
On May 18, 2021, the IRS released its highly anticipated guidance on the 100% COBRA premium subsidies (the “Subsidy”) and the related tax credit under the American Rescue Plan Act of 2021 (March 11, 2021) (“ARPA”) in Notice...more
Federal legislation and related administrative guidance enacted and issued in response to the US COVID-19 pandemic have relaxed certain requirements that otherwise apply to some health and welfare plan arrangements. This...more
On April 7, 2021, the Department of Labor (“DOL”) released initial guidance regarding the 100% COBRA premium subsidies under the American Rescue Plan Act of 2021 (“ARP”), and also issued model notices that can be used in...more