Published: March 16, 2018
Effective for any claims made on or after April 1, 2018, the decision to grant or deny benefits under an ERISA-covered plan will be governed by new rules. Since insured plans are subject to the claims procedures set forth in the insurance booklets, carriers will need to modify the claims procedures outlined in their policies and certificates of coverage. All other plans that are subject to the ERISA claims procedures will need to be reviewed and modified.
Published: March 15, 2018
For employers that maintain High Deductible Health Plans paired with Health Savings Accounts, the annual contribution limit previously announced by the IRS has been reduced for participants with family coverage under a HDHP. The change is reflected in IRS Notice 2018-18 and is the result of applying a different method for determining the Inflation Adjusted Amount, as required under the Budget Act recently passed by Congress. While the change is small, a reduction of $50 for the year, this will impact elections made by participants who wanted to “max out” for the year, requiring
Published: January 16, 2018
Members of Saul Ewing Arnstein & Lehr’s Tax and Employee Benefits and Executive Compensation Practices have outlined the recently announced 2018 dollar limits on the Social Security Wage Base, compensation and deferrals for retirement plans, and health and welfare plans, as well as PCORI fees, Medicare Part B premiums, and the Social Security full retirement age. Please click here to view a chart comparing the dollar limits for 2017 and 2018.
Published: November 15, 2017
Include all necessary interested parties in the process. This means including individuals with decision-making authority from Human Resources, Benefits, Labor Relations (if applicable), Finance, Payroll, and Legal. A collaborative effort will ensure that there is a clear understanding of the desired scope of services.
Published: November 13, 2017
The Affordable Care Act or ACA (a/k/a “Obamacare”) is not dead, yet. On November 2, 2017, FAQs 55-58 appeared, without fanfare, on the IRS’ ACA website. These FAQs outline the process the IRS will use to notify an applicable large employer (“ALE”) that a penalty under the employer mandate is being assessed. That notice will come in the form of a letter (Letter 226J), and assessment will be made based, in part, on the ALE’s reporting on IRS Forms 1094 and 1095.
Published: June 29, 2017
Lawyers with clients that deal with multiemployer plans thought we knew what plans could require withdrawing employers to pay. After all, the employer’s potential liability – commonly known as “withdrawal liability” – is described fairly comprehensively in ERISA. The US Court of Appeals for the Eleventh Circuit disagrees, and said so in a recent case. According to the court, there is nothing in ERISA that indicates Congress intended for withdrawal liability to be the only payments a withdrawing employer would ever face.