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Proposed Rule Will Expand HRA Options In 2020

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The proposed HRA rules released last week, would generally retain the current types of permitted HRAs (integrated HRAs, HRAs restricted to excepted benefits like dental and vision expenses, and retiree-only HRAs); Qualified Small Employer Health Reimbursement Arrangements (QSEHRA) and also will eventually allow two new types of HRAs effective January 1, 2020.
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Categories: Benefits in General, Health Care Reform, Compliance | Tags: HRA , QSEHRA , Premium Reimbursement Account , PRHRA , Excepted Benefit HRA , IRS , DOL , ECFC

Summary Plan Description: Paper or Electronic?

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Department of Labor (DOL) regulations describe when an employer can distribute benefit information including the Summary Plan Description (SPD), Summary of Annual Report (SAR), Summary of Benefits and Coverage (SBC), and other required benefit notices (i.e. Medicare Part D, Women’s Heath and Cancer Rights Act, Privacy Notices, etc.) electronically to plan participants.
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Categories: Benefits in General, Compliance | Tags: SPD , DOL , Summary Plan Description , Department of Labor , Electronic Distribution , Safe Harbor , Thomas v. CIGNA Group Ins , SAR , SBC , Employee Notices

ERISA Compliance: Wrap Plans and SPD Requirements

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ERISA, which is short for the Employee Retirement Income Security Act, is a set of federal laws designed to protect employees of private employers who provide pension, retirement, or profit-sharing plans; and private employers who provide insurance coverage. Wrap plans are a function of complying with ERISA’s plan document and summary plan description (SPD) requirements. Remember: Wrap plans are an easy way to create the companion ERISA language to the insurance certificates so that when dist...
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Categories: Benefits in General, Compliance | Tags: ERISA , DOL , Wrap Plans , SPD , Summary Plan Description , Plan documents , 5500 , Compliance Services
In response to an October 2017 Executive Order, the Department of Labor recently released proposed rules that would make it easier for small businesses and sole proprietors to band together to purchase and provide health insurance through association health plans.
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Categories: Health Care Reform | Tags: AHP , Association Health Plan , Department of Labor , DOL , Affordable Care Act , ACA , proposed rules , small employers
The Department of Labor (DOL) recently published the Final Rule regarding the DOL Penalties Inflation Adjustment Act Annual Adjustments for 2018 setting forth the inflation-adjusted civil monetary penalties for violations pertaining to health and welfare benefit plans and pension and retirement plans. The 2018 adjustments are effective for penalties assessed after January 2, 2018, with respect to violations occurring after November 2, 2015.
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Categories: Benefits in General, Compliance | Tags: DOL , 2018 , Penalties , Penalty , Violation , Inflation
In late August, the Office of Management and Budget approved the DOL’s proposal to extend the transition period for full implementation of the new Fiduciary Rule and related prohibited transaction exemptions by 18 months—from January 1, 2018 to July 1, 2019. The DOL also issued additional FAQ guidance relating to the Fiduciary Rule.
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Categories: Compliance | Tags: fiduciary , fiduciary rule , Department of Labor , DOL , PTE , HSA , health savings accounts , arbitration , FAQ , prohibited transaction exemptions , best interest , ERISA , Internal Revenue Code
The DOL recently announced employee benefit plan compliance guidance and relief for victims of Hurricane Maria and the October 2017 California wildfires.
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Categories: Compliance | Tags: DOL , Hurricane Maria , Puerto Rico , California , wildfires , ERISA , guidance , IRS , COBRA , relief , employee benefit plans , benefit plans , benefits , victims , Form 5500 , Hurricane , Maria
The DOL, IRS and the Pension Benefit Guaranty Corporation recently released advance informational copies of the 2017 Form 5500 series, including Form 5500-SF, schedules, and instructions.
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Categories: Compliance | Tags: Form 5500 , DOL , IRS , PBGC , 2017 , Form 5500-SF , EFAST , Schedule MB
The Department of Labor finalized new regulations that would provide additional procedural protections and safeguards for disability claimants. The new disability claims procedure regulations were supposed to take effect on January 18, 2018 and would have applied to disability claims filed on or after January 1, 2018. The DOL recently issued a final rule, however, that will delay the applicability date of the new disability claims procedure regulations by 90 days—to April 1, 2018.
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Categories: Compliance | Tags: disability , DOL , Department of Labor , delay , claims
The Department of Labor, Department of Health and Human Services and Internal Revenue Service recently issued joint interim final rules that significantly expand the types of entities that can claim an exemption from the Affordable Care Act’s requirement to provide certain contraceptive coverage without cost-sharing.
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Categories: Health Care Reform, Health Care in General | Tags: contraceptive , moral , religious , exemption , DOL , IRS , Health and Human Services , HHS , DHHS , Affordable Care Act , ACA , contraceptives
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