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Recently, companies have seen a spate of class action lawsuits challenging the legality of tobacco cessation wellness programs and related tobacco surcharges imposed by their employer-sponsored health benefit plans....more
On April 3, 2025, the U.S. Department of Labor (DOL) issued important new guidance for employers that sponsor defined benefit (pension) plans. This guidance provides new model notices and addresses several outstanding...more
On April 3rd, the Employee Benefits Security Administration (EBSA) released FAB 2025-02 and related model notices to provide some guidance for the 2024 plan year annual funding notices (AFNs). The EBSA is requiring that plan...more
New legislation liberalizing certain disclosure requirements under the Affordable Care Act (“ACA”) was passed at the end of 2024. Effective for 2024 reporting, mailing a paper copy of Forms 1095-C/1095-B is no longer...more
Plan administrators should review the following actions to be taken before the end of 2024 and focus on what to expect for 2025. The following checklist addresses plan amendments, notices, and other considerations for...more
It’s that time of year again when calendar year 401(k) plans must send annual retirement plan notices. As you work with your service providers to make sure all notices are sent, now may be a good time to reacquaint yourself...more
SECURE 2.0 has changed the game again by now allowing employers to save time and money by eliminating certain notices to be sent to unenrolled employees. In the past sponsors were required to send voluminous documents...more
One of the most common questions we receive from buy-side clients in mergers and acquisitions (M&A) is how to handle the 401(k) plan of the target company in the context of a stock purchase acquisition: Should they require...more
Warner’s Employee Benefits Practice Group is pleased to present a webinar series on significant new retirement plan legislation, the SECURE Act 2.0. While we expect implementing the new law to take several years, some...more
Sponsors of self-funded group health plans are required to notify enrollees about the availability of the plan’s notice of privacy practices and how enrollees can obtain a copy of such notice. This must be done at least once...more
Fall open enrollment is upon us, and plan sponsors and administrators are preparing to provide their employees with the required notices related to their health and welfare plans. Notice and disclosure obligations for health...more
Does your company's health plan provide prescription drug coverage? If so, you have until October 15, 2022 to send a notice to individuals who are enrolled in Medicare Part A or Part B and are eligible for the company's...more
As the end of year approaches, now is the time for safe harbor 401(k) plan sponsors to prepare their annual safe harbor notices. 401(k) Plans that satisfy nondiscrimination testing via the employer contribution safe...more
The American Rescue Plan Act of 2021 (ARPA) mandates that group health plans that are subject to COBRA must provide coverage to certain assistance eligible individuals (AEI) at no cost for periods of coverage between April 1,...more
As we mentioned in our May 23, 2021, article, the American Rescue Plan Act of 2021 (ARPA) provides a 100 percent premium subsidy for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA)...more
The American Rescue Plan Act of 2021 (ARPA) provides for a 100% COBRA premium subsidy for up to six months, from April 1, 2021 through September 30, 2021, for Assistance Eligible Individuals (AEIs) as defined under the...more
In Notice 2021-31, the Internal Revenue Service (IRS) provides broad guidance in a question-and-answer format on the application of the American Rescue Plan Act of 2021 (ARP) regarding premium assistance under the...more
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA” or the “Act”), the latest COVID-19 relief bill, into law. Under ARPA, employers will generally be obligated to advance the cost of...more
As mentioned in our earlier posts, the American Rescue Plan Act of 2021 (“ARP”) provides a 100% COBRA premium subsidy for continuation coverage between April 1 and September 30, 2021 for certain assistance eligible...more
The American Rescue Plan Act of 2021 (ARPA) provides temporary COBRA continuation coverage premium assistance for certain eligible qualified beneficiaries. On April 7, 2021, the Department of Labor issued a FAQ and model...more
The American Rescue Plan Act of 2021 (“ARPA”) provides that, for the period from April 1, 2021 until September 30, 2021, if an individual’s Consolidated Omnibus Budget Reconciliation Act (“COBRA”) qualifying event is an...more
Group health continuation coverage under the Consolidated Omnibus Reconciliation Act of 1985 (“COBRA”) permits certain group health coverage to be continued by participants and beneficiaries (“qualified beneficiaries”) when...more
The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs or had a reduction in hours (and their family...more
As described in our previous alert, the American Rescue Plan Act of 2021 (the ARPA), provides a full subsidy for COBRA premiums for certain qualified beneficiaries entitled to COBRA continuation coverage from April 1, 2021,...more