 |
 |
 |
 |
 |
Publications
5/13/2010
Client Alert—Health Care Benefits Update: Amending Plans for Adult Children; New COBRA Notices
Client Alert—Health Care Benefits Update: Amending Plans for Adult Children; New COBRA Notices
News
7/9/2010
Devilish Deadlines
Devilish Deadlines
Professionals
 |
Mark Jones
Senior Associate |
9/9/2010
Client Alert—Health Care Reform Update: New Claims Procedure Rules Go Into Effect
Author: Mark Jones
Over the last two months, the Departments of Labor, Treasury and Health and Human Services have issued a series of interim final rules implementing the provisions of the Patient Protection and Affordable Care Act (“PPACA”) that first become effective. (For information on PPACA, see our client alerts dated March 30 and May 13 and September 8 and our white paper dated July 12, 2010.) Among the most significant changes in this series are the new procedures that employers with non-grandfathered group health plans must put into place this year for the review of benefits claims.
Client Alert—Health Care Reform Update: New Claims Procedure Rules Go Into Effect
Author: Mark Jones
Over the last two months, the Departments of Labor, Treasury and Health and Human Services have issued a series of interim final rules implementing the provisions of the Patient Protection and Affordable Care Act (“PPACA”) that first become effective. (For information on PPACA, see our client alerts dated March 30 and May 13 and September 8 and our white paper dated July 12, 2010.) Among the most significant changes in this series are the new procedures that employers with non-grandfathered group health plans must put into place this year for the review of benefits claims.
9/8/2010
Client Alert—Health Care Reform Update: Changes Plan Sponsors Should Make This Year
Author: Mark Jones
Over the last two months, the Departments of Labor, Treasury and Health and Human Services have issued a series of interim final rules implementing the market reform provisions of the Patient Protection and Affordable Care Act (“PPACA”) that first become effective. (For information on PPACA, see our client alerts dated March 30 and May 13 and our white paper dated July 12, 2010.) These regulations adopt an expansive interpretation, in many respects, of the health care reform legislation and impose administrative changes that must be implemented by employers that sponsor health care plans before the commencement of the new plan year.
Client Alert—Health Care Reform Update: Changes Plan Sponsors Should Make This Year
Author: Mark Jones
Over the last two months, the Departments of Labor, Treasury and Health and Human Services have issued a series of interim final rules implementing the market reform provisions of the Patient Protection and Affordable Care Act (“PPACA”) that first become effective. (For information on PPACA, see our client alerts dated March 30 and May 13 and our white paper dated July 12, 2010.) These regulations adopt an expansive interpretation, in many respects, of the health care reform legislation and impose administrative changes that must be implemented by employers that sponsor health care plans before the commencement of the new plan year.
5/13/2010
Client Alert—Health Care Benefits Update: Amending Plans for Adult Children; New COBRA Notices
Author: Mark Jones
Several sets of health care guidance have recently been issued that require prompt employer action. Interim final rules were published today under the health care reform bill requiring employers that maintain group health plans covering children of participants to extend coverage to adult children. The IRS has issued companion guidance that permits employers to offer tax-exempt coverage of adult children retroactively to March 30, 2010, under their health plans, including cafeteria plans, provided the cafeteria plans are amended by the end of this year. The Department of Labor is also requiring employers to amend and distribute COBRA notices to employees and covered family members affected by the most recent extension of the COBRA subsidy period.
Client Alert—Health Care Benefits Update: Amending Plans for Adult Children; New COBRA Notices
Author: Mark Jones
Several sets of health care guidance have recently been issued that require prompt employer action. Interim final rules were published today under the health care reform bill requiring employers that maintain group health plans covering children of participants to extend coverage to adult children. The IRS has issued companion guidance that permits employers to offer tax-exempt coverage of adult children retroactively to March 30, 2010, under their health plans, including cafeteria plans, provided the cafeteria plans are amended by the end of this year. The Department of Labor is also requiring employers to amend and distribute COBRA notices to employees and covered family members affected by the most recent extension of the COBRA subsidy period.
3/30/2010
Client Alert—Health Care Reform—What Do Employers Need to Do, and When?
Authors: Mark Jones
The health care legislation recently enacted contains a number of provisions that require or invite employer action, including the amendment of existing employee health coverage, the preparation and distribution of communications, reports and filings, and the application of new withholding practices. Set out below is a summary of steps employers must take to ensure compliance with the Patient Protection and Affordable Care Act (“PPACA”), signed into law on March 23, 2010, and the Health Care and Education Affordability Reconciliation Act, signed into law today, and considerations for restructuring health benefits to avoid incurring unnecessary penalties.
Client Alert—Health Care Reform—What Do Employers Need to Do, and When?
Authors: Mark Jones
The health care legislation recently enacted contains a number of provisions that require or invite employer action, including the amendment of existing employee health coverage, the preparation and distribution of communications, reports and filings, and the application of new withholding practices. Set out below is a summary of steps employers must take to ensure compliance with the Patient Protection and Affordable Care Act (“PPACA”), signed into law on March 23, 2010, and the Health Care and Education Affordability Reconciliation Act, signed into law today, and considerations for restructuring health benefits to avoid incurring unnecessary penalties.
2/24/2010
Advisory—2010 Proxies: Action May Be Required to Preserve Executive Compensation Deductions
Author: Mark Jones
During the current proxy season, compensation committees of public companies will want to take into account the new position of the IRS regarding the deductibility of performance bonuses paid upon retirement or termination of employment. Committees should review their incentive pay plans to determine whether these plans need to be restructured to preserve the deductibility of performance-based bonuses before being put before shareholders.
Advisory—2010 Proxies: Action May Be Required to Preserve Executive Compensation Deductions
Author: Mark Jones
During the current proxy season, compensation committees of public companies will want to take into account the new position of the IRS regarding the deductibility of performance bonuses paid upon retirement or termination of employment. Committees should review their incentive pay plans to determine whether these plans need to be restructured to preserve the deductibility of performance-based bonuses before being put before shareholders.
1/20/2010
Advisory—Revised Model Notices for COBRA and State “Mini-COBRA” Subsidies
Author: Mark Jones
The Department of Labor has revised the model notices employers may use to inform eligible employees and family members of the temporary subsidy on premiums for continuation health care under federal COBRA and comparable state law. The revised notices reflect the extended subsidy periods put into place by the Department of Defense Appropriations Act of 2010. Plan administrators are advised to provide notice of the extensions as soon as practicable to limit the period in which eligible individuals who have reached the end of the original subsidy period may elect retroactive coverage.
Advisory—Revised Model Notices for COBRA and State “Mini-COBRA” Subsidies
Author: Mark Jones
The Department of Labor has revised the model notices employers may use to inform eligible employees and family members of the temporary subsidy on premiums for continuation health care under federal COBRA and comparable state law. The revised notices reflect the extended subsidy periods put into place by the Department of Defense Appropriations Act of 2010. Plan administrators are advised to provide notice of the extensions as soon as practicable to limit the period in which eligible individuals who have reached the end of the original subsidy period may elect retroactive coverage.
1/4/2010
Advisory—COBRA Subsidy Extended by Six Months
Authors: Susan P. Serota, Mark Jones
On December 19, 2009, President Obama signed into law the Department of Defense Appropriations Act of 2010 (the “2010 DOD Act”), which extends the maximum period in which employees who were involuntarily terminated may receive a subsidy on premiums for continuation health care (“COBRA”) coverage from nine months to 15 months. The law also extends by two months, to February 28, 2010, the period in which the termination of employment may occur in order for the employee and his or her covered family member to be eligible for the subsidy. Employers are required to provide notice of the extension to eligible individuals, including those currently receiving COBRA coverage and those who allowed their COBRA coverage to lapse when their original subsidy period expired prior to the enactment of the new law.
Advisory—COBRA Subsidy Extended by Six Months
Authors: Susan P. Serota, Mark Jones
On December 19, 2009, President Obama signed into law the Department of Defense Appropriations Act of 2010 (the “2010 DOD Act”), which extends the maximum period in which employees who were involuntarily terminated may receive a subsidy on premiums for continuation health care (“COBRA”) coverage from nine months to 15 months. The law also extends by two months, to February 28, 2010, the period in which the termination of employment may occur in order for the employee and his or her covered family member to be eligible for the subsidy. Employers are required to provide notice of the extension to eligible individuals, including those currently receiving COBRA coverage and those who allowed their COBRA coverage to lapse when their original subsidy period expired prior to the enactment of the new law.
1/29/2009
Client Alert—IRS Gives Guidance on Deferred Compensation from Offshore Funds
Authors: Timothy P. Burns, Mark Jones, Kathleen D. Bardunias
On January 8, the Internal Revenue Service (IRS) issued preliminary guidance on the taxation of deferred compensation from offshore investment partnerships and other tax-indifferent entities. Notice 2009-8, which is intended to provide interim guidance under Internal Revenue Code Section 457A until formal regulations are adopted, answers critical questions raised after the initial enactment of Section 457A and affirms that Section 457A is intended to have a wider scope in many respects than the counterpart provision on deferred compensation, Section 409A.
Client Alert—IRS Gives Guidance on Deferred Compensation from Offshore Funds
Authors: Timothy P. Burns, Mark Jones, Kathleen D. Bardunias
On January 8, the Internal Revenue Service (IRS) issued preliminary guidance on the taxation of deferred compensation from offshore investment partnerships and other tax-indifferent entities. Notice 2009-8, which is intended to provide interim guidance under Internal Revenue Code Section 457A until formal regulations are adopted, answers critical questions raised after the initial enactment of Section 457A and affirms that Section 457A is intended to have a wider scope in many respects than the counterpart provision on deferred compensation, Section 409A.
