[firm] blog logo

PBGC Modifies Payment Due Date for Large Pension Plan Flat-Rate Premiums

The PBGC, on January 3, 2014, moved the flat-rate premium due date for large single-employer and multiemployer pension plans (i.e., those with 500 participants or more) to the same date as the variable-rate premium due date for single-employer plans.?á The 2014 plan year flat-rate premiums for large calendar-year plans will be due by October 15, 2014, instead of February 28, 2014. ?áOther changes to make the premium rules more effective and less burdensome will be implemented through separate final regulations.?á A copy of the Final Regulations is available here.

Proposed Regulations Issued on Exemption for Limited Scope Dental/Vision and EAPs

Proposed regulations issued by the Departments of Treasury, Labor and Health and Human Services (the Departments) modify the excepted benefit exemption for limited scope vision and dental benefits, as well as employee assistance programs (EAPs).?á The regulations also add a new exemption for ?Ç£limited wraparound coverage.?Ç¥?á Coverages that satisfy the exemption are not subject to some of the requirements imposed by the Health Insurance Portability and Accountability Act (HIPAA) and the Patient Protection and Affordable Care Act (PPACA).?á The proposed regulations eliminate the additional employee contribution requirement for a self-insured limited scope dental or vision plan to be considered an excepted benefit, and provide specific criteria that EAPs must meet to be considered excepted benefits.?á In addition, the regulations provide a new excepted benefit exemption for ?Ç£limited wraparound coverage.?Ç¥?á Until the proposed regulations are finalized, through at least 2014, the Departments will consider dental and vision benefits, and EAPs meeting… Continue Reading

Supreme Court Upholds Limitations Period in ERISA Plan

The U.S. Supreme Court held that courts must respect the limitations period in an ERISA plan document for bringing a claim so long as it is reasonable.?á This is the case even if the limitations period starts before the cause of action accrues and not after the participant has exhausted administrative remedies under the plan.?á The participant in a disability plan had claimed that limitations periods cannot begin until after the plan?ÇÖs administrative remedies were exhausted. Heimeshoff v. Hartford Life & Accident Ins. Co., No. 12-729 (U.S. Dec. 16, 2013).?á?á Note: Although Heimeshoff involved a disability plan, the Supreme Court?ÇÖs decision would also apply to limitations periods in retirement plans.

January 2014