We are well into the Affordable Care Act (“ACA”) information reporting season. Forms 1095-B/1095-C must be provided to employees by March 1, 2024, and the deadline for electronic transmittal of Forms 1094-B/1094-C to the IRS is April 1, 2024. A
Benefits Law Update
Members of the Employee Benefits & Executive Compensation Group provide timely updates and commentary on developments affecting employee benefit plans and executive compensation arrangements. The blog is edited by Eric Altholz and Suzanne Meeker, with guest posts from other members of the group.
Latest from Benefits Law Update - Page 3
IRS Issues Practical Guidance for Implementing SECURE 2.0 Provisions
SECURE 2.0 Provisions with 2024 Implementation Dates
Proposed Regulations Regarding Long-Term, Part-Time Employees
Newly issued IRS Proposed Regulations regarding the special eligibility and vesting requirements for long-term, part-time employees provide guidance that 401(k) plan sponsors have been waiting for since these requirements were established under SECURE 1.0. Though it has been three years…
Use of Retirement Plan Forfeitures: The IRS Proposed Regulations, Recent Litigation, and the DOL’s Position
In five recently filed class action lawsuits,[1] 401(k) plan participants allege that plan fiduciaries violated ERISA by using plan forfeitures to offset employer contributions instead of paying plan expenses. The use of forfeitures to offset employer contributions is a…
HIPAA Privacy Rule Changes: Just in time for the New Year?
In 2021, the Department of Health and Human Services (HHS) proposed changes to the Privacy Rule under the Health Insurance Portability and Accessibility Act of 1996 (HIPAA) that would significantly alter the current regulations (Proposed Rules). The Proposed Rules are…
Maine’s Mandatory Retirement Savings Program: What Employers Need to Know
The Department of Labor Proposes Its New Fiduciary Rule
On October 31, 2023, the Department of Labor published a new proposed regulation (the “Proposed Rule”) defining “investment advice” for purposes of determining when someone advising an ERISA plan or participant or an IRA owner is a fiduciary.…
Retiree Medical Coverage: Just Get the COBRA Waiver
The interaction between employer-provided retiree medical coverage and COBRA[1] is complex. Many employers incorrectly assume they do not have to offer COBRA at retirement if they offer a retiree medical plan or a retiree health reimbursement arrangement (HRA), but…