Employee Benefits Law Report

Tag Archives: Department of Labor

Plan sponsors now have a deadline for providing lifetime income illustrations

Employers who sponsor 401(k) plans and other defined contribution plans in which participants may direct the investments of their accounts now have a deadline to provide lifetime income illustrations in those plans’ benefit statements. The Department of Labor (DOL) recently published guidance addressing these requirements. While helpful, the guidance is still subject to change in … Continue Reading

October 1, 2013 Health Care Reform Exchange Notice Deadline for All Employers Subject to the FLSA

As a reminder, under health care reform, all employers to which the Fair Labor Standards Act (“FLSA”) applies, not just “applicable large employers,” are required to distribute health care exchange notices to their employees by October 1, 2013. Given that health care reform is chock full of big penalties, it puzzled me that I couldn’t find a penalty for failure to provide this notice. Last week, the DOL published Frequently Asked Questions that confirmed, “there is no fine or penalty under the law for failing to provide the notice.” Nonetheless, health care reform involves so many inter-related statutes, pages of guidance, government agencies and interested parties that we encourage employers to comply to demonstrate good faith, and to avoid potential alternative theories of liability.… Continue Reading

After Earlier Grace, Departments Now Relax Certain Health Claims Procedure Requirements

Fresh off an extension this past spring of an enforcement grace period with respect to internal health claims and appeals requirements, sponsors of non-grandfathered group health plans received some more welcome news recently with the relaxation of certain group health claims procedure requirements first announced in interim final rules issued in July 2010. Although plan … Continue Reading

Department of Labor Extends More Grace on Internal Health Claims and Appeals

In Technical Release 2011-01, the Department of Labor has extended the enforcement grace period with respect to certain internal claims and appeals requirements applicable to non-grandfathered health plans under the Patient Protection and Affordable Care Act (PPACA) and its implementing regulations. The internal health claims and appeals requirements generally apply to non-grandfathered plans as of … Continue Reading
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