201702.07
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DOL Fiduciary Rule Update; May Seminar

DOL FIDUCIARY RULE UPDATE. On February 3, the President issued a Presidential Memorandum directing the Secretary of Labor to: “Examine the Fiduciary Duty Rule to determine whether it may adversely affect the ability of Americans to gain access to retirement information and financial advice. As part of this examination, you shall prepare an updated economic…

201612.22
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New Law Permitting Health Reimbursement Plans in some Small Employer Situations

As we have previously reported, the regulators take the position that, since the effective date of the ACA, employer plans that reimburse employees for individual health policy premiums and/or for medical expenses (or that pay those premiums and/or expenses directly) are unlawful, unless those reimbursement/payment arrangements are “bundled” with an underlying health plan that meets…

201411.25
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Health Plan Opt-outs and ACA Affordability – URGENT MATTER FOR HEALTH PLANS WITH A JANUARY 1, 2015 EMPLOYER MANDATE EFFECTIVE DATE

On Friday, the regulators issued new regulations that have been interpreted to provide that amounts paid by employers to employees who opt-out of the employer’s health plan must be treated as additional employee contributions for purposes of the affordability component of the ACA’s employer mandate rules. This position is a radical departure from conventional notions…

201411.03
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HPID Number Filing Deadline Delayed

As we reported on October 27, under rules related to the HIPAA electronic transaction regulations, employer-sponsored health plans, whether insured or self-funded, are required to acquire from the CMS so-called “Health Plan Identification Numbers” (or “HPIDs”).  For insured plans, the insurance carrier must obtain the HPID.  For self-funded plans, the plan sponsor must obtain the…