As mentioned in our recent blog, the date for complying with the new disability claims procedures (April 2, 2018) is rapidly approaching. In addition to making sure disability plans comply with the new rules, employers should also be reviewing other ERISA plans, such as qualified retirement plans and nonqualified deferred compensation plans to determine
Understanding Employee Benefits and key developments in the employee benefits field and items of interest to our clients. MORE
Welfare Plans
Thanks for Noticing: Disability Claims Procedure Regulations Change Notice Requirement Next Month, Impose Strict Compliance Standard
29 C.F.R. §2560.503-1
The DOL’s revised ERISA disability claims procedures regulations will be taking effect early next month, and plan sponsors should take a hard look at plan processes over the next few weeks to ensure compliance. The new requirements apply to disability benefit claims filed after April 1, 2018, after a 90-day delay postponed…
Social Security Administration Corrects and Updates Wage Base for 2018
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…
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…
Employers Who Self Administer Life Insurance Plans Had Better Do So Correctly
Many employers self-administer welfare benefit plans such as life insurance or disability insurance plans. This self administration requires the employer to determine eligibility for coverage, remit proper premiums and notify the insurance carrier about changes in coverage. The insurance carrier often does not even know the names of the covered individuals and the coverage amounts.…
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.
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 …