Takeaways
- Employers who sponsor group health plans should review and revise, as needed, their consumer-facing pricing information for any compliance issues under the Executive Orders and applicable regulations.
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Missing Participants – New State Unclaimed Property Fund Option for Small Balances
Takeaways
- On January 14, 2025, the DOL issued Field Assistance Bulletin (FAB) 2025-01, providing sponsors and administrators of ongoing defined contribution plans with a new option for missing participant balances of $1,000 or less: transfer to the state unclaimed property fund associated with the participant’s last known address.
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Exciting Update: Self-Correction for Delinquent Contributions Now Possible Under the DOL’s VFCP
Takeaways
- Plan sponsors of defined contribution plans may now self-correct the delinquent remittance of participant contributions and loan repayments when those amounts are deposited to the plan within 180 days of the pay date and the missed earnings amount is $1,000 or less.
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2025 Cost of Living Adjustments for Retirement Plans
The Internal Revenue Service recently announced its cost-of-living adjustments applicable to dollar limitations on benefits and contributions for retirement plans generally effective for Tax Year 2025 (see IRS Notice 2024-80). Most notably, the limitation on annual salary deferrals into a 401(k) or 403(b) plan will increase to $23,500, and the dollar threshold for
Conjuring Health Plan Hygiene: The Final Chapter
As we conclude our “Health Plan Hygiene” blog series, we reflect on the important insights shared about fiduciary responsibilities under the Employee Retirement Income Security Act of 1974 (ERISA) and highlight the risk posed by recent group health plan fiduciary litigation and offered strategies for mitigating these risks by meeting ERISA obligations. We have explored
Health Plan Hygiene Part 4 – Show Me the Money
Our “health plan hygiene” series has focused on steps that fiduciaries of employer-sponsored group health plans can take to ensure they meet their fiduciary responsibilities. This issue has been brought to the forefront recently due to a wave of class action lawsuits that have been brought against group health plan fiduciaries. In our last post
Health Plan Hygiene Part 3 – Best Practices for TPA Evaluation, Selection, and Contracting
A health plan’s fiduciaries are responsible for administering the health plan. Because most employers are not in the business of administering health benefits, they outsource the day-to-day health plan administration to a third-party health plan administrator (TPA). This outsourcing does not mean the employer is off the hook for their fiduciary obligations under ERISA. Even
Health Plan Hygiene Part 2: ERISA Fiduciaries – That May Mean You!
The Employee Retirement Income Security Act of 1974 (ERISA) regulates most private employee benefit retirement and welfare plans. This statute’s purview is vast; it governs employer-sponsored defined benefit and defined contribution retirement plans and an array of welfare plans.
Under ERISA, a plan fiduciary is an entity that exercises authority or control over the management
Employer-Provided Health Coverage During Employee Leaves of Absence
When an employee is on an extended leave of absence, there is often confusion regarding whether and to what extent the employer must continue to provide coverage to the employee under the employer-provided health plan. To determine whether coverage is required, the employer should consider the terms of the plan, COBRA requirements, and whether the
Use of Plan Forfeitures Not the Slam Dunk It Used to Be
A recent rash of class action lawsuits in California claim that using forfeitures to reduce future employer contributions to tax-qualified retirement plans runs afoul of the Employee Retirement Income Security Act (ERISA). These cases have continued to advance despite their central claim seeming to contradict long-standing Internal Revenue Service (IRS) guidance for the permitted use