I. Summary of the Final Rule -
On September 9, 2024, the Departments of Treasury, Labor and Health and Human Services published the much-anticipated final rule implementing parts of the Mental Health Parity and Addiction...more
The American Rescue Plan Act of 2021 (“ARPA”) includes a provision amending the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) to provide COBRA premium assistance to eligible individuals. The ARPA COBRA...more
In May 2020, the Department of Labor jointly with the Department of Treasury and the Internal Revenue Service (the “Agencies”) released guidance delaying and extending many common deadlines for employee benefit plans. In...more
In April 2011, the U.S. Department of Labor (DOL) requested information from the public on how the DOL could structure a new safe harbor for electronic disclosures under ERISA. The DOL received hundreds of comments from...more
As employers have noticed, there is a growing wave of COBRA notice class action lawsuits filed against large employers with at least six cases being filed in 2019 alone.
In each of the cases, the plaintiffs allege that the...more
On June 13, 2019, the Department of Labor (the “DOL”), along with the Departments of Treasury and Health and Human Services, released final regulations expanding the use of health reimbursement arrangements (HRAs). Since...more
On May 30, 2019, the Department of Labor released an updated form to be used to prepare the Summary Annual Report for welfare plans. The Department of Labor did not make any changes to the form, but has authorized its use...more
On May 13, 2019, the Department of Labor released additional guidance addressing questions about the enforcement relief announced earlier by the Department pending its appeal of the district court’s ruling that invalidated...more
On April 26, 2019, the Department of Labor filed a notice of appeal in the case that invalidated key provisions of its Association Health Plan (AHP) regulations.
Released last summer, the AHP regulations loosened the...more
On March 28, 2019, in State of New York v. United States Department of Labor, a federal district court in the District of Columbia set aside key portions of the Department of Labor’s final rule (the “Final Rule”) which paves...more