When an employer withdraws from a multiemployer pension plan, the plan’s trustees must notify the employer of the amount of its withdrawal liability and demand payment. Employers assessed with withdrawal liability often argue that the assessment is untimely because the trustees did not send it to the employer “as soon as practicable,” as is required
Health and Welfare Plans
Benefit Plan Deadlines Extended for Individuals Affected by Recent Natural Disasters
Last week, the U.S. Departments of Labor and Treasury issued a Joint Notice requiring the extension of certain benefit plan deadlines for individuals affected by Hurricanes Helene and Milton and Tropical Storm Helene.[1] The deadline extensions echo relief issued during the COVID-19 pandemic, but apply to a more limited group of individuals. The…
Deadlines Approaching for New ACA Section 1557 Nondiscrimination Requirements: Action Items for Covered Group Health Plans
Earlier this year, the Department of Health and Human Services (“HHS”) released a final rule under Section 1557 of the Affordable Care Act (“ACA”), which prohibits discrimination in health programs and activities. The 2024 final rule includes new administrative requirements for covered entities (which may include group health plans to the extent the plan receives…
Final Mental Health Parity Regulations Released, with Plan Sponsor Action Required by 2025
Last week, the Departments of Labor, Treasury, and Health and Human Services finalized regulations implementing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). Although the final regulations step back from certain burdensome aspects of the proposed rules (which we blogged about here), compliance with the final rules will require action from…