Health & Welfare

Court Says No Specific Wording Required in Plan Document to Give Plan Discretionary Claims Authority

The Second Circuit Court of Appeals, in Tyll vs. Black and Decker Life Insurance Program, has ruled that a plan document is not required to use any specific language in order to give the plan discretionary authority when reviewing claims against the plan.

IRS Announces 2022 HSA and HRA Limits

The IRS has announced the 2022 calendar year dollar limits for health savings account (“HSA”) contributions, the minimum deductible amounts and maximum out-of-pocket expenses for high deductible health plans (“HDHPs”) and the HRA excepted benefit limit. By law, these limits are indexed annually to adjust for inflation. 

IRS Guidance on Flexible Spending Account Relief Under CAA

The IRS has issued Notice 2021-15 (“Notice”) to provide clarification on the flexible spending account (“FSA”) relief contained in the Consolidated Appropriations Act, 2021 (“CAA”). The Notice also extends cafeteria plan election relief, and provides guidance on adopting plan amendments to implement these optional changes. 

IRS Releases 2021 Welfare Benefit Plan Limits: Health FSA and HSA Limits Increase

The IRS has released Revenue Procedures 2020-45 and 2020-32, which set forth the 2021 inflation-adjusted limits for certain employee welfare benefit plans and the dollar amounts used for certain discrimination testing. 

DOL and IRS Extend Certain Deadlines for Welfare Plans and Participants

The DOL and IRS have issued COVID-19 related guidance that temporarily extends certain deadlines applicable to welfare plans and their participants and beneficiaries.    

IRS Announces 2021 HSA Limits

The IRS has announced the 2021 calendar year dollar limits for health savings account (“HSA”) contributions, and the minimum deductible amounts and maximum out-of-pocket expenses for high deductible health plans (“HDHPs”). By law, these limits are indexed annually to adjust for inflation. 

IRS Relaxes Rules for Cafeteria Plan Mid-Year Election Changes

The IRS, in Notice 2020-29, has relaxed the mid-year election change rules for cafeteria plans due to the nature of the public health emergency imposed by COVID-19, extended grace and carryover periods for certain plans, and clarified the rules for HSA contributions.

IRS Extends Deadlines for Certain Filings and Actions for Employee Welfare Benefits Plan

The IRS has issued Notice 2020-23 to provide employers, employees and retirement plan service providers with relief from business disruptions from the COVID-19 pandemic. Notice 2020-23 automatically extends, to July 15, 2020, certain deadlines for employee welfare benefit plan filings and other specified time-sensitive actions, that would otherwise require completion between April 1, 2020, and ...

IRS Releases 2020 Limits for Welfare Benefit Plans: Health FSA and HSA Limits Increase

The IRS has released the 2020 inflation-adjusted limits for certain employee welfare benefit plans and the dollar amounts used for certain discrimination tests.

IRS Expands List of Preventive Care Benefits

IRS has issued Notice 2019-45 which expands the list of "preventive care benefits" permitted to be provided by a high deductible health plan ("HDHP") when determining if an individual is eligible to make tax-exempt contributions to a health savings account ("HSA"). In general, an individual is eligible to contribute (or have his or her employer contribute) to an HSA if he or she participates in ...