The U.S. Department of Labor (“DOL”) recently issued Field Assistance Bulletin 2012-02 which includes FAQs to assist plan administrators and service providers in complying with their obligations under the final participant level fee-disclosure regulations which apply to plans permitting participant direction of investments, such as many 401(k) plans do. The 38-question set of FAQs provides additional information on topics such as the scope of covered individual account plans, the required plan-related information to be disclosed and the method of disclosure of plan-related information, disclosures related to managed accounts, brokerage windows and funds accounted for on a unitized basis. Because plan administrators and service providers may have furnished or already prepared to furnish initial disclosures before the date of publication of Field Assistance Bulletin 2012-02, the guidance provides that for enforcement purposes the DOL will take into account whether covered service providers and plan administrators have acted in good faith based… Continue Reading
The IRS updated its informational webpage on the Patient Protection and Affordable Care Act (“PPACA”) W-2 reporting requirement for the value of health coverage. The webpage includes a useful chart presenting various types of coverage and whether or not such coverage is required to be reported on the Form W-2. The chart can be accessed here.
The U.S. Departments of Labor, Treasury, and Health and Human Services (collectively the “Departments”) issued a ten question set of FAQs addressing the Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”). The MHPAEA generally requires employment-based group health plans and health insurance issuers that provide group health coverage for mental health/substance use disorders to maintain parity between such benefits and and medical/surgical benefits. The FAQs discuss topics such as who has responsibility for overseeing MHPAEA implementation, how plans may define mental health coverage, and how the MHPAEA interacts with mental health mandates that have been imposed by various states. The FAQs can be accessed here.