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DOL Finalizes Rescission of Association Health Plan Rule

On April 29, 2024, the Department of Labor (“DOL”) released a final regulation (the “Final Rule”) that rescinded the Trump Administration rule that expanded the availability of association health plans (“AHPs”) (“Trump DOL...more

DOL Proposes Rescinding Prior Rule Relating to Association Health Plans

On December 19, 2023, the Department of Labor (“DOL”) issued a proposed rule rescinding a Trump Administration rule that expanded the availability of association health plans (“AHPs”) (the “Proposed Rule”)....more

ERISA Preemption Reaffirmed: Tenth Circuit Limits State PBM Regulation

On August 15, 2023, the Tenth Circuit issued its much-anticipated decision in PCMA v. Mulready, rejecting Oklahoma’s position that its pharmacy network requirements were not preempted by ERISA. Mulready has been closely...more

DOL Releases Field Assistance Bulletin On Disclosure Requirements for Brokerage and Consulting Service Providers Under ERISA...

Background - On December 30, 2021, the Department of Labor (“DOL”) released Field Assistance Bulletin No. 2021-03 (“FAB 2021-03”). FAB 2021-03 announces the DOL’s temporary enforcement policy for group health plan service...more

Surprise! Tri-Agencies Meet Deadline with First Set of Surprise Billing Rules, With More to Come

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (“DOL”) (collectively, the “Departments”), released the interim final...more

DOL Takes First Bite At COBRA Subsidy Guidance

On April 7, 2021, the Department of Labor (“DOL”) released initial guidance regarding the 100% COBRA premium subsidies under the American Rescue Plan Act of 2021 (“ARP”), and also issued model notices that can be used in...more

Breaking Down the “Outbreak Period” Extensions: The Clock May Begin Ticking Soon for Important Deadlines Suspended Due to COVID-19

As the COVID-19 pandemic began to overwhelm the country last spring, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) became concerned that the disruption caused by the pandemic would create...more

Employers Get Bit: Flurry of Class Action Lawsuits Allege Deficiencies in COBRA Election Notices

Recently, plaintiffs’ firms have filed a flurry of class action lawsuits against employers, alleging violations of COBRA’s election notice requirements and seeking statutory and other penalties. ...more

DOL Provides COVID-19 Relief for Retirement Plans

On April 28th, the Employee Benefits Security Administration (“EBSA”) of the Department of Labor (“DOL”), together with the Department of the Treasury, issued helpful guidance for retirement plans that extends certain...more

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