DOL Guidance

Update to Technical /guidance 01-2018: Standards for Self-Insured Non-Federal Governmental Health Plans and Insurance

Document Excerpt Summary of Updates: This Technical Release replaces the technical guidance issued January 11, 2017 with updated notice requirements for self-insured non-Federal governmental health plans and health insurance issuers offering group and individual health coverage using the Department of Health and Human Services (HHS)-administered Federal external review process. Since the January 11, 2017 technical […]

Proposed Prohibited Transaction Exemption for Credit Suisse Group

Document Excerpt SUMMARY: This document contains notice of pendency before the Department of Labor (the Department) of a proposed temporary five-year individual exemption from certain of the prohibited transaction restrictions of the Employee Retirement Income Security Act of 1974 (ERISA or the Act) and/or the Internal Revenue Code of 1986 (the Code). If this proposed […]

Advisory Opinion concluding that Ace Hardware Plan Qualifies as a AHP

Document Excerpt Thus, under the Department’s Pathway 1 sub-regulatory guidance, and assuming that the Plan is adopted and operated as described in this letter, the Ace Plan Employers would, at least in form, constitute a bona fide employer group or association in relation to the Plan for purposes of ERISA section 3(5), and the Plan […]

FAQs on HIPAA and Health Plans–Uses and Disclosures for Care Coordination and Continuity of Care

Document Excerpt Link

Electronic Filing of Notices for Apprenticeship and Training Plans and Statements for Top Hat Plans

Document Excerpt SUMMARY: This document contains final regulations that revise the procedures for filing apprenticeship and training plan notices and “top hat” plan statements with the Secretary of Labor. The final regulations require electronic submission of these notices and statements, as opposed to paper filings. The final regulations will make filing these notices and statements […]

Individual Coverage HRA Model Attestations

Document Excerpt The Departments of the Treasury, Labor, and Health and Human Services (the Departments) have issued final regulations allowing plan sponsors to offer individual coverage health reimbursement arrangements (HRAs), subject to certain requirements. Link

Model Individual Coverage HRA Notice

Document Excerpt Individual coverage HRAs may use this model notice to satisfy the notice requirement. To use this model notice properly, the HRA must provide information specific to the HRA (indicated with italicized prompts in brackets). The HRA may modify the notice based on the terms of the particular HRA. For example, if the HRA […]

FAQs on Integrating Health Reimbursement Accounts with other Coverage

Document Excerpt The new rules also increase flexibility in employer-sponsored insurance by creating another, limited kind of HRA that can be offered in addition to a traditional group health plan. These “Excepted Benefit HRAs” permit employers to finance additional medical care (for example to help cover the cost of copays, deductibles, or other expenses not […]

Final Rule on Health Reimbursement Accounts and other Account Plans

Document Excerpt SUMMARY: This document sets forth final rules to expand opportunities for working men and women and their families to access affordable, quality healthcare through changes to rules under various provisions of the Public Health Service Act (PHS Act), the Employee Retirement Income Security Act (ERISA), and the Internal Revenue Code (Code) regarding health […]

SEC Interpretation of “Solely Incidental” Prong Exclusion for Broker-Dealers

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