Seyfarth Synopsis: The billions of taxpayer dollars now flowing out to financially troubled multiemployer plans is good news for those plans, their contributing employers, and plan participants. That said, it is not a “get out of jail free” card for employers considering withdrawing from such plans. Employer beware.

Christmas came early this past year

Seyfarth Synopsis: Plans have been scrambling to gather data and work with providers in preparation for the December 27, 2022 deadline to report prescription drug and health care spending information. Just in time for the holidays, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) have issued FAQs related to Prescription Drug

Seyfarth Synopsis: Recently the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued regulations (the “Final Regulations”) which finalized previously proposed relief for furnishing Forms 1095-B and 1095-C to individuals. Notably, the Final Regulations provide a permanent 30-day extension to the due date for furnishing Form 1095-C to individuals. This extension was previously granted in the 2021 final instructions for completing Forms 1094-C and 1095-C for 2021 (see our blog here) issued in December 2021.

Continue Reading Permanent Extension to the ACA Reporting Deadline

‘Missing’ or lost participants often raise a handful of legal and administrative issues for plan sponsors. The lack of definitive guidance has led to confusion for plan sponsors in deciding what to do about missing participants. While the IRS and DOL have their own separate concerns, both agencies are concerned and likely to inquire about

Seyfarth Synopsis: The IRS has announced an increase to the applicable dollar amount for determining the Patient-Centered Outcomes Research Institute (“PCORI”) Fee for 2023 as well as other health and welfare limits.

The Affordable Care Act (ACA) established the PCORI to support research on clinical effectiveness. The PCORI is funded in part by fees paid

Seyfarth Synopsis: IRS quietly extends relief for the “family glitch” to calendar year cafeteria plans in unannounced revisions to Notice 2022-41.

In our October Legal Update (available here), we described the publication of final IRS rules fixing the so-called “family glitch” in the availability of a premium tax credit for Health Insurance Exchange (Exchange)

In December 2019, The Setting Every Community Up for Retirement Enhancement Act (SECURE Act) was enacted and signed into law. The Act was the most significant piece of legislation impacting employee benefit plans since the Pension Protection Act in 2006, and includes a plethora of changes to the laws governing employer-sponsored retirement plans, specifically impacting

Seyfarth Synopsis: The IRS just announced the 2023 annual limits that will apply to tax-qualified retirement plans. For a second year in a row, the IRS increased the annual limits, allowing participants to save even more in 2023. Employers maintaining tax-qualified retirement plans will need to make sure their plans’ administrative procedures are adjusted accordingly.

Seyfarth Synopsis: HHS has announced that the COVID-19 Public Health Emergency (PHE) has been extended another 90 days, and will run until January 11, 2023.

Seyfarth Update: On January 11, 2023, HHS announced another extension of the PHE to April 11, 2023.

In response to the COVID-19 pandemic, two separate emergency declarations have been

With interest rates on the rise, defined benefit pension plan sponsors and participants alike may be wondering how their pension plans and pension benefits are impacted. Rising interest rates lower lump sum values, which begs the question of who is impacted; the plan sponsor, the plan participant, or both? Do rising interest rates create any