Recent Posts
Blog Post
05/21/2020
By Sarah Lockwood Church and Dasha G. Brockmeyer

There is new COBRA guidance that applies to ALL GROUP HEALTH PLANS subject to federal COBRA. (See our recent client alert). Rules and FAQs were issued jointly by the IRS and DOL that reflect the COVID-19 environment and the possibility that qualified beneficiaries may not timely elect COBRA or pay COBRA premiums. This guidance essentially “stays” or “tolls” the timelines for COBRA elections for the period starting March 1, 2020 and ending 60 days after the date the President declares that the COVID-19 national emergency has ended. In the meantime, even if COBRA is not elected and/or COBRA premiums are not paid, group health care coverage for these qualified beneficiaries cannot be terminated. In separate guidance plan administrators have been given additional time to issue COBRA notices and election forms.

Blog Post
05/20/2020
By Sarah Lockwood Church and Paul A. Kasicky and Dasha G. Brockmeyer

Section 2202 of the CARES Act includes certain provisions relating to COVID-19 distributions from defined contribution plans (including 403(b) programs), and COVID-19 related loans. In Informal Guidance, the IRS has confirmed that it is optional to include these provisions in your plan.

Blog Post
05/19/2020
By Sarah Lockwood Church and Andrew J. Daly and Paul A. Kasicky

Under provisions of the CARES Act, employers are permitted to take a refundable tax credit against the employer share of Social Security taxes in the amount of 50 of the "qualified wages" with respect to each employee, up to $10,000. The maximum employee retention tax credit is therefore $5,000 per employee. Under revised IRS guidance issued May 7, 2020, FAQs 64 and 65, qualified wages include health care costs, even if the employer is not continuing to pay wages and compensation to that employee.

Blog Post
03/16/2018
By Sarah Lockwood Church

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.

Blog Post
03/15/2018
By Sarah Lockwood Church

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

Blog Post
01/16/2018
By Dasha G. Brockmeyer and Sarah Lockwood Church and Paul A. Kasicky and Robert H. Louis

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.

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