As discussed in our prior post, under the American Rescue Plan Act of 2021, certain individuals who are eligible for COBRA coverage as a result of an involuntary termination of employment or reduction in hours may be eligible...
On April 2, 2021, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) issued Frequently Asked Questions (“FAQs”) related to the implementation of the mental health and substance use disorder parity provisions under the Consolidated Appropriations Act, 2021 (“CAA”) and the Mental Health Parity and Addictions Equity Act (“MHPAEA”).
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Under the American Rescue Plan Act of 2021 (the “Act”), certain individuals who are eligible for COBRA coverage as a result of an involuntary termination of employment or reduction in hours may be eligible to receive a 100% subsidy for COBRA coverage for a six-month period beginning April 1, 2021 through September 30, 2021 (“Premium Subsidy Period”).
As discussed in our prior blog post, on April 28, 2020, the Employee Benefits Security Administration, U.S. Department of Labor, Internal Revenue Service, and Treasury Department (the “Agencies”) published joint guidance extending certain important deadlines that are otherwise applicable to employee benefit plans.
Anti-assignment clauses in ERISA health plans are useful to plan sponsors in fending off lawsuits by out-of-network providers. Federal courts have consistently upheld anti-assignment provisions contained in the plan document and/or the summary plan description (SPD); however, a recent ERISA case serves as a warning about the unintentional waiver of anti-assignment provisions.
Retirement plans of all sizes often find themselves faced with participants or beneficiaries who are either missing or do not respond to communication. The U.S. Department of Labor (“DOL”) has long been concerned with how plans try to locate and contact these ‘missing’ participants and, more importantly, how they try to prevent participants from becoming ‘missing’ in the first place.
Anti-assignment clauses in ERISA health plans are useful to plan sponsors in fending off lawsuits by out-of-network providers. Federal courts have consistently upheld anti-assignment provisions contained in the plan document and/or the summary plan description (SPD).
On December 18, 2020, the Internal Revenue Service (IRS) released final regulations (the “Final Regulations”) under Section 162(m) of the Internal Revenue Code, as amended by the Tax Cuts and Jobs Act of 2017 (“TCJA”). Section 162(m) generally limits the deductibility of compensation paid in any tax year to “covered employees” of a publicly held corporation to $1 million.
The Internal Revenue Service recently announced that it will treat contributions to single-employer defined benefit pension plans, previously extended to January 1, 2021 by the CARES Act, as timely if made no later than January 4, 2021 (which is the first business day after January 1, 2021).