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Delivering Participant Materials

The Department of Labor (DOL) requires that participant notices and other plan information ("disclosures") be provided in a way that is reasonably calculated to ensure delivery to all plan participants. The Department of Health and Human Serv…

Remember ERISA Basics: SPD and Eligibility

With all of the recent changes flowing from PPACA, it is important not to forget some very basic and long-standing aspects of plan compliance, design, drafting and administration, particularly those rooted in significant part in a law enacted 40 years …

New Model COBRA Notices Should Be Used By Employers

The Department of Labor has published a new model COBRA general notice and a new model COBRA election notice. The new model notices reflect that coverage is available in the public health insurance exchanges, i.e., the “Marketplace,” and include inform…

Compliance Recap April 2014

The IRS has released the 2015 minimums and maximums that apply to health savings accounts (HSAs) and related high-deductible health plans (HDHPs). These increases occur annually based on a cost-of-living formula. Because the inflation rate is fairly lo…

Compliance Recap March 2014

The regulatory agencies issued a number of documents during the month of March, as they have tried to provide needed information with respect to 2014 and 2015 obligations under the Patient Protection and Affordable Care Act (PPACA). Many employers will…

February Compliance Recap

February brought two significant final regulations that affect an employer’s compliance obligations under the Patient Protection and Affordable Care Act (PPACA). The first, on the employer-shared responsibility ("play or pay") requirements, d…

January Compliance Recap

Coverage first became available through the health marketplaces/exchanges on January 1, 2014, with a number of temporary provisions in effect to address some of the technical problems experienced in many of the marketplaces. Perhaps as a result of the …