On November 27, 2017, the Social Security Administration (SSA) announced that it is adjusting the maximum earnings subject to the Social Security tax for 2018 to $128,400. As we have previously posted, the SSA had announced that it would increase the maximum earnings to $128,700. The SSA made the adjustment after receiving a large
Understanding Employee Benefits and key developments in the employee benefits field and items of interest to our clients. MORE
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IRS Begins Issuing ACA Employer Mandate Penalty Notices
Recently, the Internal Revenue Service (IRS) indicated that it would begin enforcing the Affordable Care Act (ACA) Employer Shared Responsibility provisions (commonly known as the “Employer Mandate”). Last week, the IRS followed through on its promise and began mailing notices informing employers of potential liability for the 2015 reporting year.
The ACA’s Employer Mandate requires …
IRS Annual Limits on Qualified Plans for 2018
On October 19, 2017, the Internal Revenue Service released the 2018 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The Notice providing the cost-of-living adjustments is available here. The Service also announced various other inflation adjustments in a new revenue procedure (including an adjustment to the dollar limitation for…
IRS Annual Limits on Qualified Plans for 2017
IRS Annual Limits on Qualified Plans for 2017
On October 27, 2016, the Internal Revenue Service released the 2017 cost of living adjustments affecting dollar limits on benefits and contributions under qualified retirement plans and health savings accounts. Changes from 2016 were minimal. Notice 2016-62 is available here.
The following chart summarizes the 2017…
Proposed Form 5500 Changes & the new Schedule J: Big Changes for Small Group Health Plans
The US Department of Labor (DOL) has proposed changes to the Form 5500 and schedules that will affect ERISA Title I group health plans of all sizes, but small group health plans should be especially aware of the changes. Certain small group health plans (fewer than 100 participants) are currently exempt from filing the Form…
EEOC Issues New Wellness Guidance
My colleagues in the Labor and Employment Group have published an Alert on the new wellness guidance from the EEOC. It is linked here.
What You Say in Your SPD About Claims Processing Makes a Difference
Employers who self fund their medical plans often have contracts with their third party administrators about claims processing. Some of those contracts provide that the claims processor has discretion to decide claims; others provide that the claims processor is simply acting in a ministerial fashion so that the employer ultimately retains discretion to decide contested …
Bad COBRA Notices Can Cost You
Sun Trust Bank was sued in a class action challenging its COBRA notice. The plaintiffs who brought the lawsuit claimed that the COBRA notice was materially deficient in that it failed to provide the name and address of the party responsible under the plan for COBRA administration and that it failed to provide an adequate …
Time to Review Plan Subrogation Procedures, Part 2
I blogged a few days ago about the U.S. Supreme Court decision making it harder for plans to recover from a third-party settlement fund for the amount the plan paid when a participant is injured by that third-party. A recent federal district court decision highlights the need to provide appropriate notice of the plan’s reimbursement/subrogation …
Time to Review Plan Subrogation Procedures
Most self-funded ERISA medical plans provide that participants who have been injured by other people (think car accidents) must reimburse the plan if the participant recovers from the other person for those injuries. In order to obtain that reimbursement, a plan document must contain appropriate reimbursement/subrogation language and the plan must pay attention to the…