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Employer Checklist for New Health Plan Price Transparency Rules and CAA

The effective date is fast approaching for certain provisions of the Consolidated Appropriations Act of 2021 (“CAA”) and related regulations, and the Transparency in Coverage Rule. You can access previous articles written...more

COBRA Subsidies (Finally) Arrive

The American Rescue Plan Act of 2021 (the “ARPA”), which President Biden is expected to sign into law on Friday, March 12, contains several new rules impacting COBRA benefits. The ARPA provides up to six months of free COBRA...more

IRS and DOL Clarify Extended Deadlines for Benefit Plans and Encourage Employer Notices

Last year, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued two notices that extended certain benefit plan deadlines for both employees/plan participants and for plan administrators as a result of...more

Check Your COBRA Notices in Order to Avoid Potential Lawsuits

Have you thought about your COBRA notices recently? Of course not, because COBRA notices don’t warrant your valuable time. They are just another one of those pesky notices that the law requires you to send. If that was your...more

Final Disability Claims and Appeals Regulations – Be Prepared to Comply

In December 2016, the Department of Labor issued final regulations under ERISA governing claims procedures for group disability plans, which will become effective January 1, 2018. Generally, these regulations were drafted to...more

Don’t Forget to Amend Cafeteria Plan for New Permitted Election Change Events

In 2014, the Internal Revenue Service (IRS) expanded the events that would allow employees to drop their health plan coverage under their employer’s cafeteria plan. As a reminder, the general rule is that once an employee...more

Two Important Deadlines Approaching for Self-Insured Group Health Plans

If you sponsor a self-insured group health plan, then November includes two important deadlines: (1) you must obtain a health plan identifier for your plan, and (2) you must report the number of participants for whom a...more

Final “Pay or Play” Regulations Provide Transition Relief for Non-Calendar Year Plans

Last week, the IRS issued final regulations that provide additional guidance on the new “pay or play” rules (also called the employer shared responsibility rules) that will generally apply to employers’ group health plans...more

“We have to offer COBRA, When?” The “In Anticipation of Divorce” Rule

Most plan administrators know that the recipe for a group health plan’s COBRA obligation includes three ingredients – a qualifying event that occurs while the individual is covered by the plan that triggers a loss of such...more

ACA Update: Deadline for Providing Exchange Notice Delayed

The U.S. Department of Labor (DOL) recently announced that it would delay the March 1, 2013 deadline for delivery of the employer-provided notice of health insurance exchanges (Exchanges) to employees....more

Roadmap to Compliance: Navigating the Employer Shared Responsibility Rules

Earlier this month, the IRS issued proposed regulations that provide much-needed guidance on the new “pay or play” rules (also called the shared responsibility rules) that will apply to employers’ group health plans beginning...more

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