A health plan is more than a product or service; it’s a relationship. All productive and healthy relationships—especially in the benefits space—rely on trust. When an employer extends trust in a broker or insurance carrier to purchase something as critical as healthcare—for people as critical as their workers and families—we’re obligated to raise all factors … Continued
The U.S. Department of Labor’s Employee Benefits Security Administration (EBSA), the Internal Revenue Service (IRS), and the Pension Benefit Guaranty Corporation (PBGC) released advance informational copies of the 2018 Form 5500 annual return/report and related instructions. Here are some of the changes that the instructions highlight: Principal Business Activity Codes.Principal Business Activity Codes have been … Continued
Do you offer coverage to your employees through a self-insured group health plan? Do you sponsor a Health Reimbursement Arrangement (HRA)? If so, do you know whether your plan or HRA is subject to the annual Patient-Centered Research Outcomes Institute (PCORI) fee? This article answers frequently-asked questions about the PCORI fee, which plans are affected, … Continued
There’s a good chance you use a wrap document to help satisfy your Employee Retirement Income Security Act (ERISA) summary plan description (SPD) obligations. Yet if you look for a definition of wrap document in ERISA statutes or regulations, you will not find one. The wrap is not a defined term or required document; it … Continued
The Department of Labor’s new claim rules for disability benefits took effect April 2, 2018. The changes were announced over a year ago, but the effective date was delayed to give insurers, employers, and plan administrators adequate time for implementation. Although we’ve reported on the key issues in this blog previously, now seems like a … Continued
Summary plan descriptions (SPDs) are required for all retirement, health, and welfare plans subject to the Employee Retirement Income Security Act of 1974 (ERISA). However, misconceptions about this requirement are widespread. ERISA attorney Stacy H. Barrow, partner with Marathas Barrow Weatherhead Lent LLP, had a chat with ThinkHR about the importance of having proper ERISA … Continued
Q. Can we provide summary plan descriptions (SPDs) electronically? A. Yes. However, just sending them is not enough to meet ERISA requirements; you must ensure the intended recipients are actually getting them. Specifically, ERISA requires SPDs to be furnished using “measures reasonably calculated to ensure actual receipt of the material” via “methods likely to result … Continued
In its March 15, 2018, decision, the U.S. Court of Appeals for the Fifth Circuit overturned the U.S. Department of Labor’s (DOL) Fiduciary Rule that expanded the definition of an investment advice fiduciary under the federal Employee Retirement Income Security Act (ERISA). Under the Fiduciary Rule, investment brokers were going to be required to put … Continued
The DOL issued guidance for employee benefit plans, plan sponsors, and employers located in a county identified for individual assistance by the Federal Emergency Management Agency (FEMA) due to Hurricane Harvey. Because plan participants and beneficiaries may have difficulty meeting deadlines for filing ERISA benefit claims and making COBRA elections, the DOL advised plan sponsors … Continued
The U.S. Department of Labor has issued compliance guidance for benefit plans, employers and employees, and service providers who are impacted by Hurricane Harvey. The guidance generally provides relief from various ERISA requirements and time limits for entities in the disaster area. This follows the Internal Revenue Service (IRS) announcement extending certain filing dates, including … Continued
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