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106 Matching News Items
1.
The 2024 HIPAA Privacy Reproductive Health Care Regs: Takeaways for Group Health Plans
Snell & Wilmer
May 8, 2024
Snell & Wilmer
May 8, 2024
"The Reproductive Health Care Rules limit when a group health plan can disclose reproductive health care protected health information (PHI) for non-health care purposes.... A group health plan must receive an attestation for certain uses or disclosures of PHI that potentially relate to reproductive health care."
2.
Donning the Plan, Forgetting the Top Hat: A Common Oversight in ERISA Compliance
Snell & Wilmer
Apr. 9, 2024
Snell & Wilmer
Apr. 9, 2024
"If an employer realizes that it has not filed a Top Hat Statement when required, it may correct this failure using the DOL's Delinquent Filer Voluntary Compliance Program (DFVC Program).... [T]he employer must submit the late filing and a $750 user fee ... The $750 user fee applies regardless of the number of plans or the degree of lateness."
3.
2023 End of Year Plan Sponsor 'To Do' List: Executive Compensation
Snell & Wilmer L.L.P.
Dec. 17, 2023
Snell & Wilmer L.L.P.
Dec. 17, 2023
"[1] Last chance to correct certain Section 409A document failures discovered in 2023 ... [2] Nonqualified deferred compensation deferral elections should be made on or before December 31, 2023 ... [3] Take certain action to address impact of Tax Cuts and Jobs Act on Section 162(m) of the Code ... [4] Review whether equity-based compensation plans have sufficient shares remaining for 2024 awards ... [5] Review director pay practices and consider separate annual limits on director equity awards ... [6] Section 6039 of the code information statements due by January 31, 2024 ... [7] Consider clawback disclosure issues ... [8] Consider 10b5-1 disclosure issues."
4.
2023 End of Year Plan Sponsor 'To Do' List for Qualified Retirement Plans
Snell & Wilmer
Dec. 3, 2023
Snell & Wilmer
Dec. 3, 2023
"[This article] provides you with a 'To Do' List of items on which you may want to take action before the end of 2023 or in early 2024."
5.
2023 End of Year Plan Sponsor 'To Do' List for Health and Welfare Plans: Annual Cost of Living Adjustments
Snell & Wilmer L.L.P.
Nov. 29, 2023
Snell & Wilmer L.L.P.
Nov. 29, 2023
"This Part 2 describes annual cost-of-living increases and includes a summary table of penalties, percentages, and premiums under the employer shared responsibility requirements of Code Section 4980H."
6.
2023 End-of-Year Plan Sponsor 'To Do' Lists: Health and Welfare Plans
Snell & Wilmer L.L.P.
Oct. 11, 2023
Snell & Wilmer L.L.P.
Oct. 11, 2023
"[In 2024] employers will focus their compliance efforts on: [1] further implementing Consolidated Appropriations Act, 2021 (CAA) requirements; [2] updating fiduciary practices for health and welfare plans; [3] complying with the Mental Health Parity and Addiction Equity Act of 2008 ('MHPAEA') and tracking its proposed changes; [4] considering abortion-related plan design changes; and finally, [5] if any action items remain, winding down COVID-19 related group health plan changes."
7.
IRS Makes It More Difficult to Meet ACA Affordability Safe Harbors in 2024
Snell & Wilmer
Sept. 14, 2023
Snell & Wilmer
Sept. 14, 2023
"[Rev. Proc. 2023-29] lowers the affordability threshold from 9.12% in 2023 to 8.39% in 2024.... [E]mployers that rely on the federal poverty line affordability safe harbor may charge an employee premium up to $101.94 in 2024, which represents a decrease from $103.28 in 2023. Although the dollar amount may appear small, penalties for noncompliance can be significant."
8.
Another HIPAA Special Enrollment Deadline Extension: What's a Group Health Plan to Do?
Snell & Wilmer
July 31, 2023
Snell & Wilmer
July 31, 2023
"Just when you thought the confusing COVID-19 ERISA deadline extensions were behind you ... [the] Administration is calling on employers and plan sponsors to amend their group health plans to extend the 60-day special enrollment period required by HIPAA for individuals losing Medicaid and CHIP and ideally match the temporary special enrollment period on HealthCare.gov that runs from March 31, 2023 [through] July 31, 2024."
9.
Ready for Roth Catch-Up Contributions?
Snell & Wilmer
June 25, 2023
Snell & Wilmer
June 25, 2023
"Since plans are not required to permit catch-up contributions, can employers eliminate the ability to make catch-up contributions only for participants who hit the $145,000 threshold in the prior year? Can employers require all catch-up contributions to be made on a Roth basis? How does the $145,000 wage requirement work for mid-year hires?"
10.
Preparing Group Health Plans for Anticipated End of COVID-19 Emergencies
Snell & Wilmer L.L.P.
Mar. 3, 2023
Snell & Wilmer L.L.P.
Mar. 3, 2023
"[N]ext steps might include: [1] Evaluating which COVID-related benefits should continue or terminate. [2] Preparing any necessary plan amendment and/or SMM. [3] Notifying participants at least 60 days in advance of any material plan modifications ... [4] Contacting the plan's third party administrators and COBRA administrator to ensure that they are prepared to transition to pre-COVID-19 COBRA, HIPAA special enrollment, and ERISA claims and appeals deadlines. [5] Preparing any other necessary participant communications.... [6] Updating written plan procedures and administrative practices as needed."
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