On January 10, 2022 the Departments of Labor, Health and Human Services, and Treasury issued Affordable Care Act FAQs Part 51 which addresses, in relevant part, payment for over-the-counter (“OTC”) COVID-19 testing. For more information about the OTC COVID-19 testing
SW Benefits Blog
The SW Benefits Blog, published by Snell & Wilmer, focuses on employee benefits law and related regulatory developments. It covers topics such as educational assistance programs, student loan repayment benefits, fiduciary duties of plan administrators, pharmacy benefit manager (PBM) contracts, retirement plan catch-up contribution limits under SECURE 2.0, HIPAA privacy rules affecting group health plans, and ERISA compliance for deferred compensation plans. The blog provides guidance on plan design, compliance requirements, regulatory updates, and best practices for employers and plan fiduciaries managing employee benefit programs.
Latest from SW Benefits Blog - Page 5
The DOL Asks and Answers Questions About the New Welfare Plan Fee Disclosure Rules
In Field Assistance Bulletin 2021-03 (12/31/21) (FAB), the Department of Labor (DOL) issued guidance and temporary enforcement policy to address the new 408(b)(2) disclosure requirements that apply to certain service providers to group health plans. The Consolidated Appropriations Act of…
Final Touches: IRS Clarifies Impact of COVID-19 Disaster Relief on COBRA Payment Deadlines
The Internal Revenue Service recently issued guidance to clarify the interaction between COVID-19 disaster relief and premiums due for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”).
As summarized here, the Joint Notice and the…
In Case You Missed It – Summer 2021
By Anne Meyer
Summer has come and gone, but there was no summer vacation for employee benefits legislation and guidance. In case you have been too busy to check out our blogs lately, here are some key items to help you stay organized…
New Ways to Self-Correct Overpayments Under EPCRS
On July 16, 2021, IRS issued Revenue Procedure 2021-30 to update the Employee Plans Compliance Resolutions System (the “EPCRS”). The update in part expands the opportunities for plan sponsors to self-correct failures under the EPCRS by: (1) extending the self-correction…
SEC Approves Nasdaq’s Board Diversity Rules
By Greg Gautam
On August 6, 2021, the Securities and Exchange Commission (“SEC”) adopted the Nasdaq Stock Market LLC’s (“Nasdaq”) proposed board diversity rule. The rule is intended to encourage greater board diversity by requiring board diversity disclosures for Nasdaq-listed companies. As explained…
Departments Provide Some Relief to Health Plan Sponsors Facing Looming Year-End Deadlines
Year-end is always a scramble for health plan sponsors as they go through renewal and open enrollment. This year was looking to be worse than normal given the impending deadlines for complying with the transparency in coverage regulations (“TiC”) and…
Better Late Than Never: IRS Issues Guidance Clarifying COBRA Premium Subsidy Rules
S&W Insight: The IRS clarified several trailing issues with respect to COBRA premium subsidies under the American Rescue Plan Act, including extended election periods, eligibility for other coverage, and rules about allocating premium credits among employers. In addition, a notice…
Not All Surprises Are Good – Phase I of the Surprise Billing Rules
On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services, and Department of Labor issued the interim final rule “Requirements Related to Surprise Billing; Part I” (the “IFR”), which…
Updated Nonqualified Deferred Compensation Plan Audit Guide
By Greg Gautam
In June the Internal Revenue Service released an updated Nonqualified Deferred Compensation Audit Technique Guide. This updated Guide replaces the initial Guide published in 2015. While it is too early to say whether the release of the updated guidance…