On August 3, 2022, the IRS published Notice 2022-33, which extends the deadlines for amending retirement plans and IRAs to reflect certain changes to the law made by the SECURE Act; the Bipartisan American Miners Act; and section 2203 (allowing
Benefit Notes
Understanding Employee Benefits
Benefit Notes, published by Stinson LLP, focuses on legal developments and compliance issues related to employee benefit plans and retirement plans. The blog covers topics such as annual limits and cost-of-living adjustments for qualified retirement plans, risk management in retirement plan litigation, legislative changes affecting health savings accounts and flexible spending arrangements, and regulatory updates impacting health plan compliance including HIPAA and mental health parity laws. It provides guidance on plan administration, fiduciary responsibilities, and the implications of recent court rulings and federal agency actions for employers and plan sponsors.
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Temporary Extension of CARES Act Telehealth/HSA Relief Available
By Audrey Fenske & Tom Dowling
On March 15, 2022, the Consolidated Appropriations Act of 2022 (“2022 CAA”) was signed into law. Among other things, the 2022 CAA temporarily restores the telehealth relief provided under the CARES Act. The CARES Act permitted high deductible health plans…
Agencies Issue Additional Guidance Regarding Over-the-Counter COVID-19 Test Coverage
By Audrey Fenske & Tom Dowling
As indicated in our January 11, 2022 blog post and alert, the Department of Labor, the Department of Health and Human Services, and the Treasury (the “Agencies”) issued FAQs Part 51 on January 10, 2022, requiring group health plans…
Agencies Issue Guidance Requiring Coverage for Over-the-Counter COVID-19 Tests
By Tom Dowling
Beginning January 15, 2022, and through the duration of the public health emergency, insurers and group health plans must cover at-home COVID-19 diagnostic tests available over-the-counter (OTC) without imposing cost-sharing, prior authorization, or other medical management requirements. This requirement stems…
Agencies Issue COVID-19 Vaccine Incentive Guidance
By Tom Dowling
On October 4, 2021, the Department of Health and Human Services, Department of Labor and Treasury jointly issued FAQs relating to COVID-19 vaccine incentives and surcharges. Under the guidance, employers may provide incentives such as premium discounts or surcharges…
IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA
By Audrey Fenske & Sam Butler
On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the American Rescue Plan Act of 2021 (ARPA). For more information…
DOL Issues First Ever Cybersecurity Guidance
On April 14, 2021, the Department of Labor’s (DOL) Employee Benefits Security Administration issued guidance on cybersecurity for the first time to help plan sponsors, fiduciaries, service providers, and participants protect personal information and retirement assets. In the guidance, the…
DOL’s ARPA COBRA Subsidy Notices and FAQs: Stay Tuned for More
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law. Under ARPA, certain employees and their dependents who lost group health coverage during the COVID-19 pandemic due to the employee’s involuntary termination (other…
AMERICAN RESCUE PLAN ACT CONTAINS MANY EMPLOYEE BENEFITS RELATED PROVISIONS
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the “ARPA”) into law. Many of the provisions in this sweeping legislation bring changes to the employee benefits world of which employers should take note and…
IRS Guidance on Coronavirus Relief for FSAs, DCAPs, and Cafeteria Plans: Almost Anything Goes
On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (“FSAs”), and dependent care assistance programs (“DCAPs”) that were included in the Consolidated Appropriations Act (“CAA”), enacted on December 27,…