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Health Plan Hygiene Part 1: A Spoonful of Sugar Helps the Medicine Go Down

During the next several weeks, we will publish a series of articles that dive deeply into “health plan hygiene” relating to health and welfare benefit plan fiduciary issues and how employers can protect themselves in this...more

How the RMD Rules Are Like a New Puppy

On July 17, the Internal Revenue Service (IRS) issued an advance version of Notice 2023-54 (the Notice) which will include transition relief for plan administrators in connection with the change in the required beginning date...more

Workin’ 9-5, What a Way to Make a Living – 401(k) Plan Eligibility for Part-Time Employees – Part 2 of the JL SECURE 2.0 Series

On December 29, 2022, President Biden signed the Consolidated Appropriations Act, 2023, and Division T of the Act contains legislation dubbed the SECURE 2.0 Act of 2022 (SECURE 2.0). SECURE 2.0 contains an important...more

You Can’t Always Get What You Want – IRS Issues Notice 2022-33

On August 3, 2022, retirement plan sponsors welcomed IRS Notice 2022-33 (“Notice”), which extends the deadline for adopting amendments to comply with the Setting Every Community Up for Retirement Enhancement Act of 2019...more

Group Health Plan Considerations in the Face of (Potentially) Changing Abortion Laws

On May 2, 2022, a draft opinion from the U.S. Supreme Court case Dobbs v. Jackson Women’s Health was leaked to the press, and as a result the Court is expected to overturn Roe v. Wade and Planned Parenthood v. Casey,...more

Employer Vaccine Surcharges—Yes, You Can!

As employers consider implementing a vaccine mandate to encourage employees to get vaccinated against COVID-19, we have recently discussed the merits of imposing a “vaccine surcharge” on monthly health insurance premiums for...more

Money Money Money: How Much Can The Health Plan Surcharge On Unvaccinated Employees Be?

In light of the lingering COVID-19 pandemic and its impact on employee productivity and health care expenses, employers are considering imposing a premium surcharge on employees participating in the company’s health plan who...more

LGBTQ+ Protections Under The ACA Are In Effect …Again!

The Department of Health and Human Services (HHS) announced Monday it now interprets—and will enforce—Section 1557 of the Affordable Care Act (ACA) to prohibit discrimination based on sexual orientation and gender identity,...more

Special COVID-19 Health Insurance Enrollment Windows And Waivers

As a result of the ongoing COVID-19 pandemic, we are observing all sorts of never-before-seen changes in the fully-insured group health plan space. Many insurers are liberally waiving their normal rules to accommodate the...more

Implications Of COVID-19 On Your Health And Welfare Benefit Plans

Employers are grappling with employee benefit issues in response to the 2019 Novel Coronavirus (“COVID-19”). Efforts are being made to pave the way for widespread testing by eliminating cost barriers such as deductibles,...more

You’ve Discovered A Mistake In Your Plan Administration – Now What?

Occasionally qualified plan administrators discover that their plans have incurred an operational error. The Internal Revenue Service (“IRS”) recognizes that it needs the help of plan administrators to police the...more

So You’ve Filed Your 1095-C…Now What?

As companies complete their Section 6055 and 6056 reporting under the Affordable Care Act (ACA), now it’s time to be on the lookout for notices regarding ACA penalties....more

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