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About this Blog
Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.Blog Contributors
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November 15 Deadline for Self-Insured Health Plans under Reinsurance Program
The Health Care Reform Act created the transitional reinsurance program, which requires most self-insured health plans to make contributions to HHS for the 2014, 2015, and 2016 calendar years. The contribution amount is determined by the number of covered lives … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, health care reform, health plans, reinsurance, self-insured
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HIPAA Business Associates Agreements – Reminder of September 22 Deadline
On January 17, 2013, the U.S. Department of Health and Human Services (HHS) issued a final rule under HIPAA making substantial changes to the rules for vendors that provide services to HIPAA-covered plans, such as third-party administrators, pharmacy benefit managers … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged business associate agreements, Health Care, health plans, HHS, HIPAA, Privacy Rule, Security Rule, welfare plans
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Subsidized Post-Termination COBRA Benefits
Nancy Campbell recently wrote a newsletter that discussed how health care reform impacts COBRA. One of the issues that Nancy addressed is subsidized COBRA and severance arrangements. The purpose of this blog is to dive deeper into the issues employers … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 409A, COBRA, Health Care, health care reform, health plans, post-termination medical, severance
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The IRS Meant What It Said in Notice 2013-54 – Employers Who Pay For Individual Health Insurance Policies for Employees On a Pre-Tax Basis Face Massive Penalties
In our 2013 End of Year Plan Sponsor “To Do” List Part 2 – Health and Welfare I did a lengthy summary of the various changes required to employer health care arrangements on account of IRS Notice 2013-54. On May … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged DOL, Health Care, health care reform, health plans, IRS, non-integrated HRA, Notice 2013-54
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Have you updated your Summary Plan Descriptions lately?
A summary plan description, or SPD, is the document that is given to participants and beneficiaries explaining the material terms of an ERISA plan. Both pension plans and welfare plans are required to provide SPDs to participants. An SPD generally … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Qualified Retirement Plans
| Tagged health plans, qualified retirement plans, SMM, SPD, summary of material modifications, summary plan description
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Amendments Required by End of Year to Reflect Windsor Same-Sex Marriage Case
I gave a presentation last week at the Western Pension & Benefits Conference Phoenix Chapter Spring Conference entitled “Ding Dong DOMA’s Dead – The Supreme Court’s Same-Sex Marriage Ruling and Its Impact on Employee Benefit Plans.” Upon finishing my presentation, … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Qualified Retirement Plans
| Tagged DOMA, health plans, IRS, qualified retirement plans, same-sex marriage, United States v. Windsor
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Final Regs on Health Care Reform Large Employer Penalties May Help Employers Who Hire Employees From Staffing Firms
As explained in my Checklist for Employers, a large employer will have to pay a subsection (a) penalty for any month if it does not offer “minimum essential coverage” (“MEC”) to substantially all (i.e., 70% for 2015 and 95% for … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, final regulations, Health Care, health care reform, health plans, large employer penalties, MEC, minimum essential coverage
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Do you know who is in your controlled group? Employers need to know for purposes of the large employer shared responsibility penalties
Most employee benefit plans are subject to nondiscrimination rules. In order to prevent employers from breaking apart companies in order to avoid these nondiscrimination rules, most employee benefit plans, in performing nondiscrimination testing, must take into account related businesses (i.e., … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, controlled group, Health Care, health care reform, health plans, large employer penalties
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Non-integrated health reimbursement arrangements (whatever they are called) are subject to $36,500 per-participant per-year penalty
Last fall the IRS and DOL issued nearly identical guidance, IRS Notice 2013-54 and DOL Technical Release 2013-03, explaining how certain Health Care Reform Act rules apply to health reimbursement arrangements (“HRAs”). Notice 2013-54 is not good news for most … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, Health Care, health care reform, health plans, health reimbursement arrangements, HRAs
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Employers Need More Same-Sex Marriage Guidance
Last summer, the Supreme Court determined that the Defense of Marriage Act (“DOMA”) was unconstitutional. The Supreme Court’s ruling in United States v. Windsor had the effect of extending many employee benefits to same-sex spouses. Employee benefit plans were significantly … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Qualified Retirement Plans
| Tagged DOL, DOMA, health plans, IRS, qualified retirement plans, same-sex marriage, state of celebration, United States v. Windsor
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