Resources
Oct 10 2013
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Agencies Issue FAQs on Automatic Enrollment, Employer Shared Responsibility, and Waiting Periods

admin | Union Labor

On February 9, 2012, the U.S. Departments of Labor, Health and Human Services, and the Treasury released a set of Frequently-Asked-Questions (“FAQs”) relating to the  Patient Protection and Affordable Care Act’s (“PPACA”) requirements for automatic enrollment, employer shared responsibility, and the 90-day limitation on waiting periods for health coverage.  The PPACA originally required employers with […]

Oct 10 2013
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Agencies Issue Interim Final Rule on Women’s Preventive Services under Health Reform

admin | Union Labor

On August 1, 2011, the U.S. Departments of Labor, Health and Human Services, and Treasury issued an interim final rule under the Patient Protection and Affordable Care Act requiring non-grandfathered health plans to cover a wide range of women’s preventive services without cost-sharing (including, co-insurance, co-pays, and deductibles).  Theses services include well-woman visits, contraception, breastfeeding […]

Oct 10 2013
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DOL Issues FAQ on Individual Account Plan Participant-Level Fee Disclosures

admin | Union Labor

On May 7, 2012, the DOL issued Field Assistance Bulletin 2012-02 (“FAB 2012-02”), to assist plan administrators and service providers in complying with the requirements of the DOL’s final participant-level fee disclosure regulation.  The guidance contains several notable clarifications, including: (1) confirmation that if a plan provides investment and plan-related information in a single document, […]

Oct 10 2013
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Governor Cuomo Issues Executive Order Establishing Statewide Health Benefit Exchange

admin | Union Labor

On April 12, 2012, Governor Cuomo issued Executive Order No. 42, establishing a statewide Health Benefit Exchange within the New York State Department of Health.  The Exchange, which will be fully operational by January 1, 2014, will initially be financed by the federal government, and will be financially self-sustaining by January 1, 2015, as required […]

Oct 10 2013
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Client Alert: U.S. Department of Labor Issues Guidance Regarding Health Care Reform and Health Reimbursement Arrangements

admin | Union Labor

The U.S. Departments of Labor, Health and Human Services, and the Treasury recently released a set of Frequently Asked Questions (“FAQs”) regarding the application of the Patient Protection and Affordable Care Act’s (“ACA”) annual and lifetime limits to HRAs.   The ACA prohibits lifetime monetary limits on essential health benefits (“EHB”).  The ACA also prohibits […]

Oct 10 2013
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Supreme Court to Hear Oral Arguments on Constitutionality of Health Reform in March of 2012

admin | Union Labor

The U.S. Supreme Court has announced that it will hear oral arguments in the collection of cases challenging the constitutionality of the Patient Protection and Affordable Care Act (“PPACA”) from March 26 to March 28, 2012. The justices have set aside Tuesday, March 27th to hear arguments regarding the constitutionality of the PPACA’s individual mandate, […]

Oct 10 2013
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Amendment Deadline Approaches for Defined Contribution Plan Suspension of 2009 Required Minimum Distributions

admin | Union Labor

Defined contribution plans that elected to suspended required minimum distributions for 2009 under the Worker, Retiree, and Employer Recovery Act of 2009 (“WRERA”), must amend their plans to reflect the election before the last day of the plan year beginning on or after January 1, 2011.  This means that calendar year plans that suspended required […]

Oct 10 2013
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IRS Issues Guidance Proposing Employer Health Coverage Valuation Methods

admin | Union Labor

The IRS recently issued Notice 2012-31, which proposes three different methods by which sponsors of self-insured health plans may value the coverage provided under their plans.  Under the Patient Protection and Affordable Care Act (“PPACA”) employers that provide affordable “minimum essential health coverage” will not be subject to the PPACA’s employer penalties.  Minimum essential health […]

Oct 10 2013
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DOL Proposes Revisions to FMLA Regulations

admin | Union Labor

On February 13, 2012, the DOL published a Notice of Proposed Rulemaking (“NPR”) proposing regulations implementing the changes to the Family and Medical Leave Act (“FMLA”) made by the 2010 National Defense Authorization Act (“NDAA”).  The NDAA amended the FMLA to permit eligible family members of all active duty service members to take leave for […]

Oct 10 2013
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HHS Issues Final and Interim Regulations Implementing American Health Benefit Exchanges under the Patient Protection and Affordable Care Act

admin | Union Labor

On March 12, 2012, the Department of Health and Human Services (“HHS”) issued final and interim rules governing the establishment and operation of American Health Benefit Exchanges under the Patient Protection and Affordable Care Act (“PPACA”).  The PPACA requires states to establish Exchanges that will provide a competitive marketplace for individuals and small businesses to […]