Robert Projansky
Robert M. Projansky is a partner in Proskauer’s Employee Benefits & Executive Compensation Group, head of the Health Care Reform Task Force and co-head of the Hiring & Terminations Group.
Rob has a broad practice advising both multiemployer and single employer clients on all issues related to the legal compliance and tax-qualification of ERISA-covered pension and welfare plans. Rob’s clients include the largest and highest-profile U.S. media and entertainment industry clients, as well as a broad range of Fortune 500 companies.
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Over the past five years or so, Republican Congressmen have repeatedly taken steps to repeal President Obama’s landmark legislative effort – the Patient Protection and Affordable Care Act (the “ACA”). However, those efforts either failed to advance in Congress or were vetoed by President Obama. Tuesday’s Presidential and Congressional election, in which Donald Trump was … Continue Reading
Today, the U.S. Department of Labor will release its highly-anticipated Final Rule and Exemptions addressing when a person providing investment advice with respect to an employee benefit plan or individual retirement account is considered to be a “fiduciary” under the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code. According to a … Continue Reading
On December 16, 2015, the Internal Revenue Service issued Notice 2015-87 containing guidance on a wide-range of topics under the Affordable Care Act (ACA). In addition to providing guidance on affordability and COBRA matters (which will be described in subsequent blogs), Notice 2015-87 builds upon prior guidance to regulate further the use of health reimbursement … Continue Reading
As employers and plans prepare for 2016 open enrollment, they must be sure to address in their benefit design and with their third party vendors the new embedded out-of-pocket maximum limitations on individuals that were announced at the end of May by the U.S. Departments of Labor (“DOL”), Health and Human Services (“HHS”) and the … Continue Reading
On June 25, 2015, the United States Supreme Court released its much anticipated King v. Burwell decision regarding the validity of premium assistance issued by Federally-run Marketplaces. Chief Justice Roberts, writing for the 6-3 majority, agreed with the Internal Revenue Service’s (IRS) interpretation that premium assistance under the Patient Protection and Affordable Care Act of … Continue Reading
In recent talks and appearances, representatives of the U.S. Department of Labor have issued a warning about new areas of focus of DOL audits and enforcement actions. While there are a number of different enforcement priorities, we discuss two of them—health plan claims and appeals and valuation of hard to value assets— here because these … Continue Reading
Contributing employers to multiemployer plans were relieved by the Treasury Department’s interim guidance stating that they will not be subject to the employer shared responsibility payments under the Affordable Care Act (“ACA”) with respect to employees for whom they contribute to a multiemployer plan that provides minimum value, offers dependent child coverage and is affordable. … Continue Reading
On March 25, 2014, in a decision highly anticipated by employers, the U.S. Supreme Court held unanimously that certain severance payments paid to employees who were involuntarily terminated were taxable wages for purposes of the Federal Insurance Contributions Act (FICA). United States v. Quality Stores, Inc., et al., No. 12-1408 (U.S. Mar. 25, 2014). The … Continue Reading
On March 5, 2014, the Department of Health and Human Services released a Final Rule addressing, among other things, transitional reinsurance fees payable in the 2014 through 2016 benefit years. By way of background, under the Affordable Care Act (“ACA”), a transitional reinsurance fee applies to most group health plans. The transitional reinsurance fee is … Continue Reading
As previously reported, on Monday, February 10, 2014, the IRS released final regulations on the Affordable Care Act’s (ACA) employer “shared responsibility” provisions, also known as the “pay-or-play” mandate. While the final regulations have (predictably) received mixed reviews, some employers – most notably those with 50 to 99 employees or those that covered almost but … Continue Reading
Although some would argue that the next U.S. Supreme Court term is not shaping up to be as monumental as the last term, employers should have their eye on the recent decision of the Court to hear United States v. Quality Stores, Inc. The Court’s decision in this case in the next term will finally … Continue Reading
Last Friday, employers contributing to multiemployer plans received some good news. As expected, the Internal Revenue Service amended the transition rule for 2014 originally set forth in its proposed regulations on the pay or play mandate. (The new text of the rule can be found here). An employer required by a collective bargaining agreement to contribute to … Continue Reading
Election Results Likely to Result in the End of the ACA as We Know It, But Employers and Plan Sponsors Should Stay the Course for Now
By Steven Weinstein, Robert Projansky and Damian A. Myers on Posted in Affordable Care Act
U.S. DOL To Issue Final Rule and Exemptions on Fiduciary Standards
By David Picon, Ira G. Bogner, Russell Hirschhorn and Robert Projansky on Posted in Department of Labor, Fiduciary
IRS Notice 2015-87 (Part 1) – IRS Issues New HRA Integration Rules
By Damian A. Myers and Robert Projansky on Posted in Affordable Care Act
Reminder: Non-Grandfathered Plans Must Implement Embedded Out-of-Pocket Maximums
By Lisa Schlesinger and Robert Projansky on Posted in Affordable Care Act
King v. Burwell – Supreme Court Upholds Premium Subsidies under Federally-Run Marketplaces; ACA Remains (Mostly) Unfazed
By Robert Projansky, Paul M. Hamburger and Damian A. Myers on Posted in Affordable Care Act, Supreme Court
DOL’s New Audit Focus? Health Plan Claims and Appeals and Hard to Value Assets
By Emily Erstling and Robert Projansky on Posted in Department of Labor
Contributing Employers to Multiemployer Plans Are Not Off the Hook – Tracking the Full-Time Status of Employees
By Emily Erstling and Robert Projansky on Posted in Affordable Care Act, Multiemployer Funds
Supreme Court Finds Severance Payments are Subject to FICA
By Elizabeth M. Mills, Nathan Bentley and Robert Projansky on Posted in Federal Insurance Contributions Act, Severance
More Multiemployer Plan Relief – Final Rule Exempts Self-Insured/Self-Administered Plans from Transitional Reinsurance Fee in 2015 and 2016
By Robert Projansky on Posted in Affordable Care Act, Multiemployer Funds
Relief for Multiemployer Plans (and the Employers That Love Them)
By Peter Marathas and Robert Projansky on Posted in Affordable Care Act
Supreme Court to Decide Whether RIF-Related Severance Pay Is Subject to FICA
By Elizabeth M. Mills and Robert Projansky on Posted in Federal Insurance Contributions Act, Reduction in Force, Severance
IRS Clarifies Applicability of Pay or Play to Multiemployer Plans’ Contributing Employers
By Robert Projansky on Posted in Affordable Care Act, Articles, IRS
