Understanding Employee Benefits

EEOC Challenges Honeywell’s Wellness Program

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The EEOC recently sued Honeywell International, Inc., claiming that Honeywell’s wellness program violated the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA). Although the EEOC sued two other employers for wellness program violations before it sued Honeywell, this is the first case where the agency seems... Read More

Topics: Health Care Reform, Health Plan

Attention All You Procrastinators!

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The Centers for Medicare and Medicaid Services (CMS) has postponed to 11:59 pm on December 5, 2014, the deadline for health insurance issuers and self funded plans to submit their annual enrollment count for the transitional reinsurance program. The deadline was otherwise November 15, 2014. The payment deadlines of January... Read More

Topics: Health Care Reform

Filed Your 2013 Health and Welfare Plan 5500s? Did you Include Your M-1 Attachments?

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A provision of the Affordable Care Act of 2010 (ACA) included additional reporting requirements and greater U.S. Department of Labor (DOL) oversight of Multiple Employer Welfare Arrangements (MEWAs). The DOL’s Employee Benefits Security Administration (EBSA) issued final rules earlier in 2014 which clarified the requirements for initial and annual Form... Read More

Topics: Cafeteria Plans, Form 5500s, Health Care Reform, Health Plan, Welfare Plans

MARCH 2014 – IRS Issues Final “Pay or Play” Regulations

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On February 12, 2014, the Treasury Department issued final regulations for the employer shared responsibility (“pay or play”) requirement under the Affordable Care Act (proposed regulations were issued in December of 2012). The regulations provide a large number of clarifications and transition relief – this article highlights several important transition... Read More

Topics: Health Care Reform

More About HRAs and Some About EAPs

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I blogged recently about IRS and Department of Labor (DOL) guidance restricting the ability of employers to subsidize individual health insurance premiums for their employees after December 31, 2013. That IRS and DOL guidance also addressed a few other issues. The guidance provides that HRA amounts credited to an employee... Read More

Topics: Health Care Reform, Health Plan