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Article

Hodgson Russ LLP | USA | 31 Oct 2011

Agencies issue summary of benefit coverage guidance

The Department of Labor (DOL), Department of the Treasury, and Department of Health and Human Services (HHS) jointly issued proposed regulations regarding the Summary of Benefit Coverage (SBC).

Article

Morgan Lewis | USA | 26 Aug 2011

New summary of benefits and coverage required for health plans in 2012

On August 22, the Departments of Treasury, Labor, and Health and Human Services (the Departments) jointly published proposed regulations on the new Summary of Benefits and Coverage (SBC) that insurers and group health plan administrators will be required to distribute beginning next year.

Article

Eversheds Sutherland (US) LLP | USA | 29 Dec 2010

IRS issues guidance delaying enforcement of nondiscrimination rules for insured health plans

On December 23, 2010, the IRS issued Notice 2011-1 regarding the application of the nondiscrimination rules under Internal Revenue Code (Code) section 105(h) to non-grandfathered insured group health plans pursuant to the Patient Protection and Affordable Care Act (PPACA).

Article

Seyfarth Shaw LLP | USA | 1 Sep 2010

Agencies issue guidance for external review and appeals procedures

As we stated in Issue 11, for plan or policy years beginning after September 23, 2010, the IFRs require that nongrandfathered group health plans and health insurance issuers provide updated internal claimsappeals processes and external review processes.

Article

Baker & Hostetler LLP | USA | 31 Aug 2010

Regulatory agencies publish interim procedures for federal external review processes for non-grandfathered self-insured health plans and model notices for internal appeal and external review determinations

Non-grandfathered self-insured group health plans now have guidance regarding the new requirements for federal external reviews of adverse benefit determinations.

Article

Katten Muchin Rosenman LLP | USA | 6 Apr 2010

DOL issues safe harbor rule for timely deposit of contributions to small plans

The Department of Labor recently published a final rule that allows employee benefit plans with fewer than 100 participants to comply with time limits for the segregation and deposit of participant contributions to employer-sponsored pension and welfare benefit plans.

Article

Dorsey & Whitney LLP | USA | 8 Mar 2010

New regulations reaffirm plan assets should be deposited as soon as reasonably possible but provide some relief for small plans

The Department of Labor ("DOL") issued new regulations on January 14, 2010 (75 Fed. Reg. 2068) confirming earlier regulations and guidance that plan assets should be contributed to an employee benefit plan on the earliest date the amounts can reasonably be separated from the employer’s general assets.

Article

Stinson LLP | USA | 8 Feb 2010

Labor department approves new safe harbor for depositing employee contributions

Under current labor regulations last amended in 1996, sponsors of qualified retirement and health and welfare plans are required to transfer employee contributions withheld from wages as soon as those amounts can be reasonably segregated from the employer’s general assets, but not later than the 15th business day of the month following the end of the month in which the amounts would otherwise have been paid in cash.

Article

Holland & Knight LLP | USA | 27 Jan 2010

New safe harbor for timing of participant contributions to plans with less than 100 participants

On January 14, 2010, the U.S. Department of Labor (DOL) published a final rule that provides a safe harbor for when participant contributions forwarded from an employer to a plan will be treated as having been contributed in a timely manner (the “New Contribution Rule”).

Article

Katten Muchin Rosenman LLP | USA | 22 Jan 2010

DOL issues safe harbor rule for timely deposit of contributions to small plans

Last week, the Department of Labor (DOL) published a final rule which allows employee benefit plans with fewer than 100 participants to comply with time limits for the segregation and deposit of participant contributions to employer-sponsored pension and welfare benefit plans.

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