Mary Grace Richardson
Mary Grace Richardson is an associate in the Labor & Employment Department and a member of the Employee Benefits & Executive Compensation Group. She counsels clients on a myriad of issues related to employee retirement and health plans.
Mary Grace received her J.D. and diploma in comparative law, summa cum laude, from Louisiana State University Paul M. Hebert Law School. At LSU, she served as a senior editor of the Louisiana Law Review, was a member of the Board of Advocates, and was a member of the Order of the Coif.
Prior to joining Proskauer, Mary Grace clerked for Chief Judge S. Maurice Hicks, Jr. in the United States District Court for the Western District of Louisiana.
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On January 31, 2022, the Ninth Circuit affirmed the lower court’s finding that surcharges imposed by the Pension Protection Act (“PPA”) are excluded from the determination of an employer’s “highest contribution rate” for withdrawal liability payment calculations. While the Multiemployer Pension Reform Act (“MPRA”) explicitly excluded surcharges that accrued after 2014 from such calculations, this … Continue Reading
On December 30, 2021, the U.S. Department of Labor (“DOL”) issued Field Assistance Bulletin No. 2021-03 (“FAB”), announcing its temporary enforcement policy for group health plan service provider disclosures under ERISA section 408(b)(2)(B). The Consolidated Appropriations Act of 2021 (“CAA”) amended ERISA section 408(b)(2) to require “covered service providers” to disclose all direct or indirect … Continue Reading
The Internal Revenue Service (“IRS”) recently issued proposed regulations affecting certain reporting deadlines under the Patient Protection and Affordable Care Act (“ACA”). Specifically, proposed regulations would make permanent an automatic 30-day extension for issuing Forms 1095-B and 1095-C to covered individuals and employees, which would otherwise be due by January 31. The proposed regulations also … Continue Reading
As a follow up to our previous alert on the American Rescue Plan Act of 2021, we have summarized the key aspects of the recently released PBGC and IRS guidance on the new Special Financial Assistance Program for troubled multiemployer pension plans in our latest client alert, which can be found here.… Continue Reading
On May 18, 2021, the IRS released Notice 2021-31 (the “Notice”) providing guidance on the temporary 100% COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”), summarized generally here. The Notice addresses how to calculate the premium subsidy and the corresponding tax credit available to premium payees, as well as the rules … Continue Reading
The American Rescue Plan (“ARP”) offers a special 60-day election period for certain individuals who previously declined or discontinued COBRA coverage (“Assistance Eligible Individuals” or “AEIs,” as defined in ARP). These individuals may elect COBRA coverage prospectively, beginning April 1st, at no cost, as long as they are not eligible for Medicare or other group … Continue Reading
The American Rescue Plan Act of 2021 (“ARPA”) includes a 100% COBRA premium subsidy for “assistance eligible individuals,” for periods of coverage occurring between April 1, 2021 and September 30, 2021, as described in earlier blog posts. An “assistance eligible individual” is any COBRA “qualified beneficiary” who loses group health coverage on account of a … Continue Reading
Today, the House of Representatives passed the $1.9 trillion American Rescue Plan Act of 2021 (the “ARPA”). The ARPA has already been approved by the Senate and is expected to be quickly signed into law by President Biden. We recently published a client alert addressing Title IX, Subtitle H of the new legislation, which includes … Continue Reading
The recently enacted Consolidated Appropriations Act of 2021 (“CAA”) requires new disclosures for brokers and other consultants providing services to certain group health plans. Under the CAA, “covered service providers” must disclose their “direct” and “indirect” compensation above $1,000 received during the term of the contract or arrangement to a responsible plan fiduciary of a … Continue Reading
The problem of “missing” participants and beneficiaries (individuals for whom the plan administrator does not have adequate contact information) is an ongoing issue for retirement plan administrators. It is also an area to which the DOL has dedicated significant attention in recent years, particularly in its enforcement actions, which has been a challenge for administrators. … Continue Reading
Ninth Circuit Agrees with Third Circuit that “Highest Contribution Rate” for Withdrawal Liability Payment Calculations Excludes PPA Surcharges
By Justin Alex and Mary Grace Richardson on Posted in PBGC, Withdrawal Liability
DOL Announces Temporary Enforcement Policy and Guidance to Address New Compensation Disclosure Requirements for Service Providers to Group Health Plans
By Neal Schelberg, Mary Grace Richardson and Andrea Ewalefo on Posted in Department of Labor, Disclosure
IRS Proposal Extending Deadlines for ACA Reports to Individuals
By Robert Projansky, Katrina McCann and Mary Grace Richardson on Posted in Affordable Care Act, Health Plan Compliance, IRS
PBGC Releases Guidance on New Special Financial Assistance Program for Troubled Multiemployer Plans
By Ira Golub, Robert Projansky, Justin Alex and Mary Grace Richardson on Posted in PBGC
Calculating the ARP COBRA Premium Subsidy Tax Credit
By Roberta Chevlowe, Katrina McCann and Mary Grace Richardson on Posted in COBRA
ARP COBRA Subsidy Special Election Opportunity: Who Gets a Second Bite at the Apple, and How Do They Take It?
By Roberta Chevlowe, Katrina McCann and Mary Grace Richardson on Posted in COBRA
Some Family Members May Not Be Eligible for the ARPA COBRA Premium Subsidy
By Paul M. Hamburger, Roberta Chevlowe and Mary Grace Richardson on Posted in COBRA, Coronavirus
COVID-19 Stimulus Bill to Include Significant Pension Reforms and Expand Scope of 162(m) Compensation Deduction Limit
By Ira Golub, Robert Projansky, Andrea Rattner, Justin Alex and Mary Grace Richardson on Posted in Client Alert, Coronavirus
ERISA Disclosure Requirements for Service Providers Extended to Group Health Plans
By Neal Schelberg, Anthony Cacace and Mary Grace Richardson on Posted in Disclosure
DOL Releases Guidance on Addressing the Missing Participant Problem
By Mary Grace Richardson and Joshua E. Stephens on Posted in Department of Labor
