News & Analysis as of

U.S. Treasury Employee Benefits Proposed Regulation

Davis Wright Tremaine LLP

New Guidance Issued on Mandatory and Optional Catch-Up Provisions Under SECURE 2.0

New guidance facilitates the implementation and operation of two important SECURE 2.0 features: mandatory Roth catch-up contribution rules for high-income participants, and the optional "super" catch-up contributions...more

Kilpatrick

IRS Issues Proposed Regulations Regarding Mandatory Auto-Enrollment Under SECURE 2.0

Kilpatrick on

The IRS and Treasury Department recently issued proposed regulations addressing the mandatory automatic enrollment provisions under the SECURE 2.0 Act of 2022 (SECURE 2.0). The proposed regulations generally adopt the...more

Patterson Belknap Webb & Tyler LLP

New Proposed Catch-Up Contribution Regulations Answer Many Questions

Background - Many defined contribution plans are designed to permit participants to take advantage of an increased employee contribution limit starting the year they turn 50....more

McDermott Will & Schulte

Anticipating the MHPAEA Final Regulations: A Word About Network Composition

If our trade and industry sources have it right, we could see final regulations implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), as most recently amended by the Consolidated Appropriations Act, 2021...more

McDermott Will & Schulte

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...more

McDermott Will & Schulte

The MHPAEA Proposed Rule: Scalability and the Plight of the Small(er) Self-Funded Plan

After a brief hiatus to discuss the pleading standards adopted by the US Court of Appeals for the Tenth Circuit in E.W. v. Health Net Life Insurance Company, we return to our examination of the comments submitted in response...more

McDermott Will & Schulte

The Proposed MHPAEA Regulations: A Comment on the Comments

McDermott Will & Schulte on

In our last post, we considered some of the comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and...more

McDermott Will & Schulte

The “Meaningful Benefit” Requirement for NQTLs Under the Proposed MHPAEA Regulations

In previous posts, we reported on proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the Departments of Labor, Health and Human Services, and the Treasury (collectively, the...more

Seyfarth Shaw LLP

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Seyfarth Shaw LLP

Mental Health Request for Public Comment Spoiler Alert – The Departments Need Help

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Ballard Spahr LLP

Details Upon Details: Compliance Under MHPAEA’s New Proposed Regulations

Ballard Spahr LLP on

Summary - The Departments of Labor, Health and Human Services, and the Treasury have proposed regulations under the Mental Health Parity Act that build on prior guidance to set forth requirements for an extremely detailed...more

McDermott Will & Schulte

Treasury, DOL and HHS Issue Landmark Mental Health Parity Proposed Rule

The US Departments of the Treasury, Labor, and Health and Human Services (the Departments) recently issued much-anticipated proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) to better...more

McDermott+

Biden Administration Issues Proposed Reg to Clarify and Enforce Mental Health Parity Requirements

McDermott+ on

Another week, a lot more regs! Last week, the US Departments of Health and Human Services, Treasury and Labor (the Departments) released a proposed reg related to mental health parity requirements for health plans. This week,...more

Ballard Spahr LLP

New Mental Health Parity Guidance Issued

Ballard Spahr LLP on

Summary - On July 25, 2023, the Departments of Labor, Treasury, and Health & Human Services (the Departments) released joint proposed regulations and other guidance under the Paul Wellstone and Pete Domenici Mental Health...more

McDermott Will & Schulte

Changing the Rules of the Game for Retirement Plans

Earlier this year, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations on the use of forfeitures by tax-qualified retirement plans. The changes, published in the Federal Register,...more

Jackson Lewis P.C.

IRS Gets Its Act Together For Forfeiture Rules

Jackson Lewis P.C. on

The February 24, 2023, issuance by the IRS of proposed regulations on the use of forfeitures in qualified retirement plans provides some welcome clarity, regulatory house cleaning, and relief for plan sponsors. With a...more

Holland & Hart - The Benefits Dial

One Way or Another … Forfeitures Will Have to Be Administered Under Your Retirement Plan, and the IRS Just Proposed New...

On February 27, 2023, the Treasury issued proposed regulations intended to simplify and clarify the rules relating to forfeitures within qualified retirement plans. Defined Benefit Plans - Similar to defined...more

McDermott Will & Schulte

Weekly IRS Roundup February 20 – February 24, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 20, 2023 – February 24, 2023. ...more

McDermott Will & Schulte

Proposed IRS RMD Regulations Present Challenges, Risks for 403(b) Plans

The Internal Revenue Service (IRS) is strategically working to execute the statutory changes that were outlined by the Setting Every Community Up for Retirement Enhancement Act (SECURE Act) of 2019. However, the IRS’s efforts...more

Mintz - Employment Viewpoints

Treasury Department and IRS Proposed Individual Coverage HRA Affordability Safe Harbors

As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more

Proskauer - Employee Benefits & Executive...

New HRA Regulations Part 5 – More on the Employer Shared Responsibility Mandate

On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more

Troutman Pepper Locke

Final Regulations Issued for Hardship Distributions From Qualified Retirement Plans

Troutman Pepper Locke on

As we wrote in November 2018, the Treasury Department issued proposed regulations that significantly relaxed many rules governing hardship distributions from qualified plans, including eliminating requirements that employee...more

McDermott Will & Schulte

Weekly IRS Roundup August 19 – 23, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more

Miller Canfield

Proposed Hardship Distribution Regulations Mean Changes for 401(k) and 403(b) Plan Sponsors

Miller Canfield on

Employer-sponsors of certain retirement plans have work to do prior to the end of 2019. Sponsors of Internal Revenue Code ("Code") section 401(k) and 403(b) plans must analyze their plan documents and associated...more

Holland & Knight LLP

IRS Adds 2019 Updates to Operational Compliance List

Holland & Knight LLP on

• The Internal Revenue Service (IRS) has updated its Operational Compliance List for retirement plans with a number of changes that take effect in 2019, with a focus on changes to hardship distributions. • The Operational...more

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