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Reproductive Health Care: A Future in Flux with the Next Administration

Access to reproductive health care has been a part of the national debate for years, and even more so since 2022 when the US Supreme Court issued its ruling in Dobbs overturning decades of precedent established under Roe v....more

Agencies Release Final Mental Health Parity Rule

On Monday, September 9, 2024, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued their final rule regarding the nonquantitative treatment limitation (NQTL) comparative analysis...more

Does Section 1557 Apply to Employer Group Health Plans? (And — Why That Question May Not Even Matter)

Seyfarth Synopsis: Following years of back and forth, new final rules were published by the Department of Health and Human Services (HHS) on May 6, 2024 reinstituting the Department’s interpretation that the prohibition on...more

Agencies Defer Final Action on Junk Insurance, While Suggesting Caution Against One Last “Binge”

The agencies have finalized a portion of their proposed rules impacting so-called “junk insurance” regarding short-term limited-duration insurance, but deferred finalizing the more significant changes that would have impacted...more

Employers Consider Post-Dobbs Playbook in Dealing with Alabama Ruling on IVF Treatments

Seyfarth Synopsis: Last week, the Alabama Supreme Court ruled that cryogenically frozen embryos are children and are protected from destruction under state law. This is the latest in a series of post-Dobbs judicial rulings...more

Wellness Apps and Privacy

Employers looking to enhance their suite of employee benefit programs, and focused on lessons learned during the pandemic on wellbeing, are interested in providing greater access to wellness tools. And, the vendors who...more

The Long Wait for the Long-Term Part-Time Guidance is Over

Seyfarth Synopsis: It’s here for your post-Thanksgiving turkey hangover reading pleasure! The Department of Treasury and IRS released on Friday (in the middle of most people’s long holiday weekend) their proposed rules for...more

My Insurance Doesn’t Cover That? Agency Guidance on “Junk Insurance”

Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance...more

Multiple Cyber Incidents Impact Employee Benefit Plans and Participants

By this point, most people in the employee benefits space have heard about the MOVEit and Retirement Clearing House (RCH) cyber incidents, which could directly impact employers’ benefit plans. The MOVEit file transfer...more

FICA Tax Avoidance Wellness Program Viewed Unfavorably by 87,000 New IRS Agents

Seyfarth Synopsis: Just like a bad penny, schemes promising employers ways to reduce their FICA tax burden, and maybe their employees’ income tax burden at the same time, keep popping up with a slightly different burnish on...more

New Guidance on Gag Clause Attestation

Seyfarth Synopsis: The Consolidated Appropriations Act, 2021 (“CAA”) contains a requirement that that group health plans may not have agreements with service providers that would restrict certain information that the plan may...more

Do We Finally Have a Final Answer on ESG Investments and ERISA’s Fiduciary Duties?

Seyfarth Synopsis: At the end of November, the DOL issued final regulations on ERISA’s fiduciary duties when investing plan assets. According to the DOL, these final regulations retain the longstanding core principles that...more

Leaked Opinion Becomes Reality — Roe v. Wade is Overturned

Culminating a flurry of late June opinions released by SCOTUS this week, the court today in Dobbs v. Jackson Women’s Health Organization has taken the extraordinary step of ending decades of precedent surrounding the...more

SECURE 2.0: Here We Go Again

Seyfarth Synopsis: The SECURE Act, passed just before the onset of the COVID-19 pandemic at the end of 2019, significantly altered the retirement plan landscape. For a reminder on how the SECURE Act changed the retirement...more

How Do You Really Feel? DOL Talks ESG and Crypto

Seyfarth Synopsis: In keeping with their recent more vocal stance on fiduciary duties, the Department of Labor has weighed in on the wisdom of 401(k) plans including an ESG fund or a crypto investment option in its line-up....more

Another Swing in DOL Investment Position

Seyfarth Synopsis: Reminiscent of the DOL’s about-face on ESG investing by ERISA fiduciaries [discussed here], this week the DOL has issued a “supplemental statement” on its view of the use of private equity investments in...more

Feeling Like a Yo-Yo? Latest Swing in ESG Investments and ERISA’s Fiduciary Duties

Seyfarth Synopsis: For those of you following the saga of ERISA’s fiduciary duties and ESG investing, we are nearing a possible finish line. The latest turn in the saga came when the DOL issued a new set of proposed...more

Audio Recordings Are Up for the Taking!

Seyfarth Synopsis: The DOL has waded into a long-simmering debate about whether audio recordings of phone calls between a plan participant and the plan’s administrator or insurer should be provided to the participant when...more

Yes, Your Health FSA Can Cover Your Surgical Mask Purchase!

Seyfarth Synopsis: Avid readers of Beneficially Yours may recall that just over a year ago we asked the pressing question of whether surgical mask purchases could be covered under a health care FSA, among other “novel”...more

DOL Issues Clarification of Outbreak Period - Sort of

At the 11th hour, on February 26, 2021, the Department of Labor (DOL) issued EBSA Disaster Relief Notice 2021-01 (the “Notice”) to provide guidance on the duration of the COVID-related relief previously provided by the DOL in...more

Waistbands Aren’t the Only Thing Requiring Flexibility During the Pandemic: IRS Clarifies Guidance on Latest FSA Provisions and...

Seyfarth Synopsis: The Consolidated Appropriations Act of 2021 (“CAA”) offers significant relief for employers sponsoring flexible spending accounts (for a more detailed description of those changes, check out our alert). ...more

EEOC Wellness Rules Proposed, Water Bottle Enthusiasts Rejoice

Synopsis: For years, employers have struggled to understand what level of incentives in wellness programs might be considered “voluntary” under the Americans with Disabilities Act (ADA). ...more

Yes, I Know it’s a Pandemic, But What About ERISA?!?!?!? Benefits Implications in Employer-Sponsored COVID Vaccine Programs

Synopsis: Now that we have two approved vaccines (and several more on the horizon) employers are starting to explore whether they should require their employees to get vaccinated in order to report to work. ...more

IRS Provides Additional Clarity on Key SECURE Act Provisions

On December 20th, before the outbreak of COVID-19 and the resulting pandemic, President Trump signed into law the Setting Every Community Up For Retirement Enhancement Act of 2019 (the “SECURE Act”) and the Bipartisan...more

To Vote or Not to Vote — That is the Question

Seyfarth Synopsis: On the heels of the Department of Labor’s June proposed regulation throwing cold water on plan fiduciaries’ selecting investments in the environment, social and governance (ESG) space, the agency has now...more

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