Health & Welfare

EEOC Explains Application of ADEA to ICHRAs

On January 7, 2021 the Equal Employment Opportunity Commission (“EEOC”) issued an opinion letter explaining the application of the Age Discrimination in Employment Act (“ADEA”) to individual coverage health reimbursement arrangements (“ICHRAs”).

Stimulus Package Makes Major Changes with Respect to Employer Sponsored Benefit Plans

By Dannae Delano, Barry Salkin and Roberta Casper Watson

Agencies Issue Final Grandfathered Group Health Plan Regulations

The Department of Labor, Department of Health and Human Services, and the IRS (collectively, the “Agencies”) have issued final regulations providing greater flexibility to plan sponsors that wish to retain their group health plans’ “grandfathered” status under the Affordable Care Act (“ACA”).  The final regulations are substantially unchanged from the earlier proposed regulations.

Agencies Issue Further Guidance on COVID-19

The Department of Labor, Department of Health and Human Services, and the IRS (the “Agencies”) have issued Frequently Asked Questions #43 (“FAQs”) regarding implementation of the Families First Coronavirus Response Act (the “FFCRA”), the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), and other health coverage issues related to COVID-19.

DOL Issues Revised COBRA Notices

The Department of Labor (“DOL”) has issued updated versions of its model general notice and model election notice to ensure that qualified beneficiaries better understand the interactions between Medicare and COBRA.

Federal Agencies Extend Deadlines for COBRA and Health Plan Claims, Appeals, and Special Enrollments

In coordination, the Department of Labor, the Department of Health and Human Services, and the Internal Revenue Service (collectively, the “Agencies”) have extended deadlines for multiple events important to health plan administration that will apply to ERISA-governed plans and governmental plans.  Third-party administrators and COBRA administrators will need to program for these extensions, and ...