READ TIME: 5 MINUTES The Department of Labor (DOL) recently released a final rule providing the adjusted civil penalty amounts for certain health and welfare plan violations assessed after January 15, 2024. The Employee Retirement Income Security Act (ERISA) provides for the imposition of penalties for a number of plan-related failures or administrative errors and […]
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DOL Announces 2024 Penalties for Benefit Plan Compliance Errors
READ TIME: 5 MINUTES Since 2015, federal agencies have been required to annually review the laws and regulations they enforce to adjust applicable penalties for inflation. These adjustments, or so the theory goes, provide higher incentives for plan sponsors to ensure their benefit plans and programs remain compliant. Specifically, the U.S. Department of Labor (DOL) […]
Read moreDOL Announces 2023 Penalties for Health & Welfare Plan Compliance Errors
READ TIME: 4 MINUTES Since 2015, federal agencies have been required to annually review the laws and regulations they enforce to adjust applicable penalties for inflation. These adjustments, or so the theory goes, provide higher incentives for plan sponsors to ensure their benefit plans and programs remain compliant. Specifically, the U.S. Department of Labor (DOL) […]
Read moreDOL Announces Good Faith Enforcement Standard, Provides Guidance on Compensation Disclosures
READ TIME: 5 MINUTES The Consolidated Appropriations Act, 2021 (CAA) amended Section 408(b)(2) of the Employee Retirement Income Security Act (ERISA) to require service providers (including brokers) to disclose direct and indirect compensation to group health plan fiduciaries. Field Assistance Bulletin No. 2021-03 (FAB) states that the U.S. Department of Labor (DOL) has set a […]
Read moreFamilies First Coronavirus Response Act Notice – Labor Posters Mandatory Update
A mandatory labor law notice has been released – the Families First Coronavirus Response Act Notice. This notice must be displayed in the workplace and emailed to those working from home by April 1. The mandatory posting applies to “All employers covered by the paid sick leave and expanded family and medical leave provisions of […]
Read moreProposed Rules on Coverage and Transparency and Final Rules on Hospital Price Transparency
On November 15, 2019, the Internal Revenue Service (IRS), Department of Labor (DOL), and the Department of Health and Human Services (HHS) (collectively, Departments) released proposed rules on coverage transparency. The proposed rules seek to give an estimate of plan participants’ potential cost-sharing liability for covered items and services they might receive from a particular […]
Read moreCompliance Recap – July 2019
July was a busy month in the employee benefits world. The Internal Revenue Service (IRS) released a notice that expands the list of preventive care benefits a high deductible health plan can provide without a deductible or with a deductible below the annual minimum deductible. The IRS also released the indexed affordability percentage for plan […]
Read moreCompliance Recap – June 2019
June was a relatively busy month in the employee benefits world. The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury published final rules that removed the prohibition against integrating a health reimbursement arrangement (HRA) with individual health insurance coverage and recognized certain HRAs as limited excepted […]
Read moreTri-Agency Final Rules on Health Reimbursement Arrangements (HRAs)
The Department of the Treasury (Treasury), Department of Labor (DOL), and Department of Health and Human Services (HHS) (collectively, the Departments) released their final rules regarding health reimbursement arrangements (HRAs) and other account-based group health plans. The DOL also issued a news release, frequently asked questions, model notice, and model attestations. The final rules’ goal […]
Read moreCompliance Recap – May 2019
May was a busy month in the employee benefits world. The Internal Revenue Service (IRS) released health savings account annual contribution limits and high deductible health plan minimum annual deductibles and annual out-of-pocket maximums for 2020. The Department of Labor (DOL) released questions and answers (Q&As) to clarify its enforcement of the association health plan […]
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