On Monday, the U.S. Court of Appeals for the Fifth Circuit issued an administrative stay of enforcement of the district court decision in Braidwood Management Inc. v. Becerra. Readers of our earlier blog (found here) will remember that in Braidwood, the district court enjoined enforcement of the preventive services mandate for “A” or “B” items … Continue Reading
The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently released guidance for group health plans on required preventive services coverage. The guidance was issued in response to a federal district court decision in a case called Braidwood Management, Inc. v. Becerra that enjoined enforcement of the preventive services mandate for items … Continue Reading
Important Update: Based on informal comments from the U.S. Department of Labor, it appears that the tolling of benefit plan deadlines will end on July 10, 2023, as described in our earlier blog on this subject, notwithstanding the legislation that was signed on Monday ending the COVID-19 National Emergency on April 10th. As explained in … Continue Reading
Update: On April 10, 2023, President Biden signed into law legislation ending the COVID-19 National Emergency prior to the previously announced May 11, 2023 date. See our blog on this new development here. The legislation does not impact the end of the COVID-19 Public Health Emergency. Earlier this week, the Departments of Labor, Treasury, and Health … Continue Reading
The Biden Administration recently announced that the COVID-19 National Emergency will end on May 11, 2023. This means that the requirement to extend various benefit plan deadlines due to the COVID-19 pandemic will end as well. By way of brief background, early during the pandemic, the U.S. Departments of Labor and Treasury adopted relief pursuant to which … Continue Reading
As previewed in our prior blog post, the recently enacted SECURE Act includes many changes that affect employer-sponsored benefit plans and require the attention of plan administrators. Among these changes, effective for distributions made after December 31, 2019 (for individuals who reach age 70½ after that date), is the delay of the “required beginning date” … Continue Reading
At the heart of tax qualified retirement plan compliance is a requirement to timely adopt plans and plan amendments. Failure to adopt plan amendments when required can result in plan disqualification. Accordingly, it is very important for plan sponsors to prove that amendments were properly executed in a timely manner. In a General Legal Advice … Continue Reading
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