Earlier this month, the DOL released its first updates to the model COBRA Notices since 2014. The new notice does not reflect any legal changes, but instead provides more information regarding the interaction of COBRA and Medicare. The new notices explain there may be advantages to enrolling in Medicare rather than COBRA. And it highlights that ...
As mentioned in our blog last week, the Department of Labor has finally released updated regulations on electronic disclosure; for the first time since 2002! These regulations provide a new safe harbor method of electronic distribution. Needless to say, these regulations are very welcomed (given the vast amount of technological changes that ...
Earlier this month, the Department of Labor/Employee Benefits Security Administration and the IRS (the “Agencies”) issued a Joint Rule to extend certain time frames as a result of the COVID-19 pandemic. As discussed in previous posts, the Joint Notice requires that all benefit plans subject to ERISA extend various participant deadlines ...
Among the many pages of DOL issued guidance and relief for plan sponsors one provision has avoided a lot of attention. In Notice 2020-21, discussed in some of our other blog posts, in addition to the extension of certain time frames, the DOL provided an extension of deadlines for providing retirement and welfare plan notices to participants.
The ...
While it may be too early to be thinking about next year for some and hard to think about anything but dealing with the pandemic, others are already knee deep in making health plan changes for 2021. For those already planning for next year, the IRS just announced the new 2021 contribution limits for a health savings account (“HSA”), as well as ...
Just moments after hanging up the phone with a client confirming for them that there has been no relief under Section 125 on mid-year changes that are not HIPAA special enrollment events , the IRS issues Notice 2020-29 and Notice 2020-33 providing guidance that makes the advice I gave 5 minutes before invalid. We are on the fastest freight train of ...
To echo my colleague in another post, in nearly 20 years of practice I have never seen so much benefits related guidance in such a short period of time. It seems like just yesterday the IRS and DOL issued a joint notice providing some deadline relief for COBRA and HIPAA related matters. Today, we receive more complex guidance when the IRS released Notices
As mentioned in our prior blog post, the DOL and IRS have recently issued coordinated guidance that provides relief for benefit plans by extending certain deadlines. This post examines the limited relief granted to retirement plans by extending the amount of time a plan has to distribute participant contributions and loan repayments into ...
Have you ever experienced an employee attempting to enroll their spouse a month and a half after getting married or an employee attempting to enroll a newborn child 40 days after the birth? Normally, these enrollments would not be permitted given that the employee notified you outside of the 30-day HIPAA special enrollment window. Well along ...
This week the DOL and IRS issued a joint rule which provides relief from certain deadlines for group health plans, other welfare benefit plans, and retirement plans. The guidance applies to all plans covered by ERISA or the Code, and HHS has announced it will extend similar relief to non-federal governmental health plans. This post examines the ...