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
Understanding Employee Benefits and key developments in the employee benefits field and items of interest to our clients. MORE
Health Plan
New Law Permits Stand-Alone Health Reimbursement Arrangements (HRAs) For Small Employers
By Todd Martin on
On December 13, 2016 President Obama signed into law the 21st Century Cures Act. The law had been approved with bipartisan support in the House by a vote of 392 to 26 and in the Senate by a vote of 94 to 5. The law addresses a number of health care issues such as…
IRS Annual Limits on Qualified Plans for 2017
By Stinson LLP on
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
By Stinson LLP on
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
By Stinson LLP on
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
By Stinson LLP on
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
By Stinson LLP on
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
By Stinson LLP on
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
By Stinson LLP on
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…
EEOC Loses Another Wellness Case, Part 2 – Beware the ACA Penalties
By Stinson LLP on
In my last blog post, I discussed a recent loss by the EEOC in its efforts to limit the ability of employers to require employees to complete health risk assessments (HRAs) or biometric screenings in order to enroll in the employer’s health plan. I said that I would discuss an Affordable Care Act (ACA)…