Model Exchange Notice and Revised COBRA Election Form
As noted in our client alert, the DOL recently released guidance on the Exchange/Marketplace notice required to be issued to existing employees no later than October 1, 2013. Followers of PPACA developments will recall that this notice was originally scheduled [...]
Affordability Calculation Undermines Wellness Programs Beginning in 2015
The Affordable Care Act requires that employers offer affordable health care coverage to full-time employee beginning January 1, 2014 (or pay a penalty). Coverage is affordable if the employee’s contribution toward self-only coverage does not exceed 9.5% of his or [...]
SBCs: Few Changes and (Mostly) Extended Relief
On Tuesday, the PPACA triumvirate of DOL, Treasury/IRS and HHS issued a new set of FAQs (number 14, for those still counting) covering changes to the Summary of Benefits and Coverage. The only changes (as emphasized in multiple places in [...]
Cover Your ERISA Obligations with a Wrap
ERISA requires that all plans have a written plan document and summary plan description. In addition to describing the benefits, the written plan document must also establish: a funding policy, a procedure for allocating administrative and management responsibilities, a procedure [...]
DOL, HHS and Treasury Agree; 90 Days Does Not Equal 3 Months
For plan years beginning on or after January 1, 2014, a health plan cannot impose a waiting period of more than 90 days. Earlier this month, the Departments of Labor and Health and Human Services and Treasury (the “Departments”) followed [...]
Fiduciary Tips for Monitoring Your Target Date Retirement Funds
Target date retirement funds generally refer to a related group of investment funds that automatically rebalance and become more conservative as a participant moves towards a designated retirement year. Many 401(k) and profit sharing plans use target date retirement funds [...]
The DoL’s ACA Compliance Checklist
The Department of Labor’s Employee Benefits Security Administration recently released a self-compliance tool for group health plans, in the form of a checklist, on its website (available here). The checklist is a good summary of the ACA requirements, as far [...]
ACA FAQs Part XII – Preventive Care Rules
As discussed in our prior post, the Department of Treasury/IRS, Department of Labor, and the Department of Health and Human Services (the “Departments”) recently issued its twelfth set of Frequently Asked Questions addressing cost-sharing limitations and a slew of preventive [...]
Health Reform FAQs Part XII on Cost-Sharing Limits
The Department of Treasury/IRS, Department of Labor, and the Department of Health and Human Services (the “Departments”) recently issued its twelfth set of Frequently Asked Questions. As Kevin Knopf, Special Counsel at the U.S. Treasury Department, once observed, the FAQs [...]
The President’s Budget Attack on the Supposed “Loophole” of Saving for Retirement
The administration views certain savings for retirement to be a tax loophole. The just released budget, in its Overview, states: “[The budget] ends a loophole that lets wealthy individuals circumvent contribution limits and accumulate millions in tax-preferred retirement accounts.” [There [...]