The Bottom Line Almost a year after the SECURE 2.0 Act of 2022 was enacted as part of the Consolidated Appropriations Act, 2023, the IRS released guidance (Notice 2024-2) in the form of a grab bag Q&A aptly named “Miscellaneous Changes Under the SECURE 2.0 Act of 2022.” The Notice covers Continue Reading
Employee Benefit Considerations When Making Workforce Modifications
The Bottom Line Employers should work closely with ERISA counsel to ensure that employee benefit plans (e.g., non-qualified deferred compensation plans, health and welfare plans, and 401(k) plans) are being administered correctly as they make changes to their workforce.Employers should work with Continue Reading
Key 2022 Updates for Health and Welfare Plans
The Bottom Line Employers should carefully review and prepare for 2022 compliance modifications and new requirements, and should monitor future developments. In particular, the IRS may start more aggressively pursuing ACA penalties and taxes against employers if the good faith transitional Continue Reading
Plan Coverage of At-Home COVID-19 Testing
The Bottom Line Effective January 15, 2022, plan coverage of FDA-approved over-the-counter at-home COVID-19 diagnostic tests is mandatory. Plan sponsors should immediately contact their pharmacy benefit managers to set up mechanisms for direct coverage of at-home tests.If any questions Continue Reading
IRS Provides Much Needed Guidance on COBRA Premium Subsidy
The Bottom Line ARPA’s COBRA subsidy presents a number of complicated administrative issues that employers, plan sponsors and administrators, and insurers alike should consider. In particular, there are a number of nuances to how the Notice may impact plan sponsors.Plan sponsors should consult with Continue Reading
COBRA Changes Under the American Rescue Plan Act of 2021
The Bottom Line President Biden signed the American Rescue Plan Act of 2021 (the Act) into law on March 11, 2021. While direct payments to certain taxpayers and extending unemployment benefits have received most of the attention in the media, the Act also provides for the federal government to Continue Reading
Regulators Clarify COVID-19 Relief Deadline Extension
The Bottom Line Plan sponsors and administrators have been grappling with how to handle the possible expiration of the extension relief granted for certain deadlines applicable to group health plans under the “Joint Notice” published in May 2020 (the 2020 Guidance). With just two days to go Continue Reading
New York State’s Budget Amends the NY Home Care Worker Wage Parity Law
The Bottom Line The 2020-21 New York state budget bills include significant amendments to the New York Home Care Worker Wage Parity Law, including new rules regarding distributions, certifications and WTPA notices and wage statements, as well as new enforcement provisions for failures to comply Continue Reading
IRS Provides Cafeteria Plans with Flexibility Due To COVID-19
The Bottom Line Employers are rightfully concerned that many of their employees are dealing with a host of serious financial issues caused by COVID-19. Employers have been further frustrated that Internal Revenue Service (IRS) rules have prevented them from relieving their employees’ stress by Continue Reading
Retirement Plans: Regulators Provide Relief from Certain ERISA Requirements During the COVID-19 Crisis
The Bottom Line The Notice provides valuable relief from the DOL’s enforcement of certain requirements under Title I of ERISA. However, the Notice does not affect a participant or beneficiary’s enforcement rights under ERISA.Much of the relief provides that enforcement actions will generally not be Continue Reading