The U.S. Department of Labor (DOL) announced two settlements with major insurance companies this month that highlight the importance of employers avoiding the collection of group life insurance premiums from employees until the insurer has approved them for coverage, including receipt and approval of required evidence of insurability (EOI). These settlements follow two similar agreements
Benefit Notes
Understanding Employee Benefits
Blog Authors
Latest from Benefit Notes
HHS Supports Reproductive Health Care Privacy by Modifying the HIPAA Privacy Rule
By Lisa Rippey
The Department of Health and Human Services’ (“HHS”) Office for Civil Rights recently published a final rule (the “Final Rule“) which provides additional privacy protections related to the use and disclosure of reproductive health care information. Covered entities (e.g., health plans) and their business associates must comply with all of the provisions of…
Annual Limits on Qualified Plans for 2024
By Lisa Rippey
On November 1, 2023, the Internal Revenue Service (IRS) released Notice 2023-75, which sets forth the 2024 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments earlier this year…
IRS Announces Delay of Implementation of SECURE 2.0 Act’s Roth Catch-up Contribution Provision for Two Years
By Sam Butler
As signed into law, Section 603 of the SECURE 2.0 Act of 2022 (“SECURE 2.0”) required that effective as of January 1, 2024, participants in 401(k) plans, 403(b) plans, or governmental 457(b) plans, who were age 50 or older and whose Social Security wages for the previous year exceed $145,000 (indexed), only be permitted to…
Preparing for the End of the COVID-19 Emergency Declarations: Part II. Considerations for COVID-19 Vaccine Coverage
By Lisa Rippey
As explained in part I of our Preparing for the End of the COVID-19 Emergency Declaration series, the Public Health Emergency (“PHE”) and National Emergency (“NE”) are coming to a close. While the Biden Administration had initially announced its intent to end the NE on May 11, 2023, on April 10, 2023, President Biden signed…
Preparing for the End of the COVID-19 Emergency Declarations: Part I. Considerations for COVID-19 Diagnostic Testing Coverage
On January 30, 2023, the Biden Administration announced that it intends for the National Emergency (“NE”) relating to the COVID-19 pandemic to end on May 11, 2023. Shortly after, the Secretary of the Department of Health and Human Services announced the intent to end the Public Health Emergency (“PHE”) on the same day. The end…
Departments Provide Relief for 2020 and 2021 Prescription Drug Reporting
On December 23, 2022, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) issued FAQs providing relief from prescription drug and health care spending reporting requirements. The FAQs are available here: https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-56.
As part of the Consolidated Appropriations Act, 2021, group health plans and issuers must annually report to the Departments…
Just in the Nick of Time – Congress Grants Second Extension of CARES Act Telehealth/HSA Relief
Recently Congress passed the Consolidated Appropriations Act of 2023 (“2023 CAA”). Among other things, the 2023 CAA extends, for a second time, the telehealth relief provided under the CARES Act. The CARES Act permitted high deductible health plans (“HDHP”) to provide first-dollar telehealth services or other remote care services. This allowed individuals covered under a…
Congress Delivers SECURE 2.0 for the Holidays
By Mark Wilkins
Revised January 11, 2023
Congress made several changes to retirement plans as part of the Consolidated Appropriations Act of 2023, which recently passed both the House and Senate. The final bill contains several provisions affecting retirement plans under Division T of the bill titled “Secure 2.0 Act of 2022.” An official summary of all…
Annual Limits on Qualified Plans for 2023
By Lisa Rippey
On October 21, 2022, the Internal Revenue Service (IRS) released Notice 2022-55, which sets forth the 2023 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. Earlier this year, the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments were announced in Revenue…