Multiemployer benefit plans generally require contributing employers to submit “remittance reports” that identify the employees that performed covered work, the type of work performed, and the amount of time worked. Plans rely on the timely and accurate submission of these reports to ensure employers remit all required contributions and that participants accrue all benefits owed.
Health and Welfare Plans
Down to the Wire: Will We Have HSA with Pre-Deductible Telehealth in 2025?
By Amanda Karpovich & Jennifer Rigterink on
Important Update—Pre-Deductible Telehealth HSA Relief Ends on December 31, 2024: As discussed in our post below, although extension of the telehealth safe harbor was included in various bill drafts, the year-end spending bill signed into law on December 21, 2024 (American Relief Act, 2025) does not include pre-deductible telehealth relief. This means that the…
Sixth Circuit Adopts IRS Standard to Determine Whether Activity Constitutes “Trade or Business” for Withdrawal Liability Purposes
By Neil V. Shah & Anastasia Gellman on
Under 29 U.S.C. § 1301(b)(1), all “trades or businesses” under common control with an employer that has withdrawn from a multiemployer pension plan are jointly and severally liable for the employer’s withdrawal liability. The statute does not define what it means to be a “trade or business,” and though the statute references regulations promulgated by the…
Third Circuit Affirms Finding that Withdrawal Liability Assessment Was Untimely
By Neil V. Shah & Jessica Wang on
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…