COVID-19 Relief Extends Certain Employee Benefit Plan Deadlines

On April 28, 2020, the Departments of Labor (DOL) and the Treasury (Departments) issued deadline relief to help employee benefit plans, plan participants, and plan service providers impacted by the COVID-19 outbreak. This Compliance Overview summarizes the participant deadline extensions affecting COBRA continuation coverage, special enrollment periods, claims for benefits, appeals of denied claims, and…

Proposed Rules Clarify Individual Coverage HRAs

On September 30, 2019, the IRS published proposed regulations to clarify the application of the employer mandate under the Affordable Care Act (“ACA”) and certain nondiscrimination rules under the Internal Revenue Code (“Code”) Section 105(h) to health reimbursement arrangements (“HRAs”) integrated with individual health insurance coverage (individual coverage HRAs, or “ICHRAs”). Notably, the proposed regulations…