Plan documentation: do I give it or not? *

USA - February 19 2013
I frequently am asked by plan sponsors and plan administrators about how to respond to a request for "plan documentation." Under Section 104(b)(4) of…

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DOL audit letters revised for PPACA: asking for specifics *

USA - February 12 2013
By off chance, a client sent me a letter from the Department of Labor conducting an audit of their self-funded health plan. While I have responded to…

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The new and improved HIPAA/HITECH rules: what employers need to know *

USA - February 7 2013
On January 25, the new (final?) rules about HIPAA Privacy under the HITECH Act were issued in the Federal Register. While the effect of the new rules…

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Proposed rules issued on religious institutions and contraceptives *

USA - February 4 2013
One component of PPACA that has been hotly contested is the provision of birth control expenses and its impact on religious-affiliated groups opposed…

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More on PPACA: multiemployer plans and shared responsibility *

USA - January 28 2013
Earlier this month, Treasury and the IRS published a proposed rule regarding the shared responsibility penalty. The proposed rule describes how the…

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