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Departments Press Pause on Final Mental Health Parity Regulations

Yesterday, the Departments of Labor, Treasury, and Health and Human Services announced a non-enforcement policy with respect to final regulations issued under the Mental Health Parity and Addiction Equity Act of 2008...more

Employer Benefit Plan Assistance FAQs: California Wildfires

In the wake of the horrific wildfires in Los Angeles (which are ongoing as of today), employees based in the Los Angeles area may have questions about available support from employer-sponsored 401(k) plan accounts and other...more

IRS Proposes 401(k) Plan Regulations Implementing Long-Term Part-Time Employee Eligibility Requirements

The day after Thanksgiving, while many of us were fortunate enough to be reaching for leftover pie, the IRS released proposed regulations implementing the requirement that 401(k) plan sponsors permit “long-term part-time...more

Sixth Circuit Concludes Lack of Proper Delegation Means Benefits Department Did Not Have Discretionary Authority to Decide Claims

A recent Sixth Circuit decision emphasizes the importance of maintaining correct benefit plan delegations to avoid tussles over the correct standard of review for benefit claims. In this case, the Sixth Circuit concluded...more

For HDHPs, IRS Confirms Pre-Deductible COVID-19 Testing Coverage Will End Next Year

In the most recent sign that special COVID-19 benefit plan rules are drawing to a close, last Friday, the IRS issued Notice 2023-37, which clarifies the scope of COVID-19 testing and treatment that can be provided on a...more

Update: Big Headline, Small Impact: Legislation Ends COVID-19 National Emergency

Important Update: Based on informal comments from the U.S. Department of Labor, it appears that the tolling of benefit plan deadlines will end on July 10, 2023, as described in our earlier blog on this subject,...more

SECURE 2.0 Act of 2022 Arrives: (Another) Landmark Retirement Package

The wait is over for SECURE 2.0, a long-awaited (and debated) package of retirement plan reforms.  Today, Congress passed the “SECURE 2.0 Act of 2022” as part of the 2023 Consolidated Appropriations Act; President Biden is...more

After Dobbs v. Jackson Women’s Health Organization: Impact on Employee Benefits

Employers and other group health plan sponsors are left with much to consider following the U.S. Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, which overruled the Supreme Court’s prior landmark...more

Post-Dobbs: FAQs for Employers and Other Benefit Plan Sponsors

Can group health plans continue to provide coverage for abortion-related expenses? In short, yes. Dobbs does not prohibit group health plans from covering abortion-related expenses. Instead, Dobbs eliminates federal...more

IRS Unveils New Pre-Examination Compliance Pilot Program for Retirement Plans

Ever wished you could predict the future? Or at the very least, predict the timing of a retirement plan audit? Well, you may be in luck on your second wish. Last Friday, the IRS Employee Plans division announced a new...more

There’s More! Tri-Agencies Provide Clarifying Guidance on Group Health Plan Coverage of Over-the-Counter At-Home COVID-19 Tests

A few short weeks ago we told you in a blog post that, with only four days’ notice, the Departments of Labor, Treasury, and HHS (the Departments) required that, starting January 15, 2022, group health plans cover FDA-approved...more

You Can Go Home Again: Tri-Agencies Release New Group Health Plan Coverage Requirements for Over-the-Counter At-Home COVID-19...

Looking forward to the weekend? Many employers and plan administrators may also have been . . . up until yesterday, when the government issued new requirements that take effect on Saturday. ...more

EPCRS Update Offers New Tools to Correct Retirement Plan Errors

The IRS recently updated its “Employee Plans Compliance Resolution System” (EPCRS).  By way of background, EPCRS is a correction program administered by the IRS for plan sponsors to correct certain retirement plan errors. ...more

A Practical Guide to Claiming the COBRA Premium Assistance Tax Credit

Over the last few months, employers and plan administrators have concentrated on identifying qualifying individuals eligible for COBRA premium assistance under the American Rescue Plan Act of 2021 (“ARP”), sending out proper...more

Guide to New IRS Guidance on COBRA Premium Subsidy

On May 18, 2021, the IRS released Notice 2021-31, which provides implementation guidance on the COBRA premium subsidy available under the American Rescue Plan Act of 2021 (ARP). As discussed in our prior blog posts, ARP...more

The Wait is Over: Treasury and IRS Release COBRA Premium Subsidy Guidance

Today, the Treasury Department and the IRS released detailed questions and answers providing guidance on various implementation issues related to the COBRA premium subsidy under the American Rescue Plan Act of 2021 (ARP)....more

The Pocket Guide to COBRA Subsidy Notices

The American Rescue Plan Act of 2021 (ARP) requires that plan administrators distribute new COBRA notices to individuals in connection with the COBRA premium subsidy...more

DOL Releases COBRA Premium Subsidy Model Notices – With a Few Surprises

Immediate Action Required - As discussed in our prior posts, the American Rescue Plan Act of 2021 (“ARP”) requires that plan administrators distribute new COBRA notices advising individuals of their possible rights to a...more

ARPA COBRA Subsidy – Special Second Election Period (Two Bites at the Apple and Some Additional Food for Thought)

The American Rescue Plan Act of 2021 (“ARPA”) provides a 100% COBRA premium subsidy for “assistance eligible individuals” for periods of coverage occurring between April 1, 2021 and September 30, 2021. An “assistance...more

Department of Labor Finalizes New Safe Harbor for Electronic Delivery of Retirement Plan Disclosures

On May 21, 2020, the U.S. Department of Labor (the “DOL”) finalized its proposed regulation expanding electronic delivery for retirement plan disclosures. On balance, the final regulation is generally consistent with the...more

IRS Expands Mid-Year Change Opportunities for Health and FSA Benefits and Increases Carryover Limit

On May 12, 2020, the IRS released Notice 2020-29, which provides significant flexibility for health insurance and flexible spending account election changes during 2020, and Notice 2020-33, which increases the amount that may...more

ERISA Newsletter - First Quarter 2020

Editor’s Overview - Of course, on the top of everyone’s minds these days is COVID-19. In this edition of Proskauer’s ERISA Newsletter, our colleagues discuss some of the legislation and guidance that has been issued over...more

ERISA Newsletter - Fourth Quarter 2019

Editor's Overview - Happy New Year. We wrap-up 2019 with an article that reflects on significant developments in ERISA litigation during 2019, and takes a look at what's on the horizon for 2020. The courts (at all levels)...more

New Year, New World: A Short Guide to the SECURE Act for Retirement Plan Sponsors and Administrators

The SECURE Act, included as part of the Further Consolidated Appropriations Act, 2020, was signed into law on December 20, 2019. This new law contains many significant changes that may impact employer-sponsored benefit plans....more

New IRS Guidance for Tax-Exempt Entities Funding Employee Benefits

The IRS recently released a final regulation clarifying how voluntary employees’ beneficiary associations (VEBAs) and supplemental unemployment benefit trusts (SUBs) should calculate unrelated business taxable income. VEBAs...more

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