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Updated SBC Guidance and FAQs Released

On April 24, 2013, the DOL issued a set of FAQs, together with a new template, for the summary of benefits and coverage (SBC) that applies to group health plans and individual health insurance issuers. The new rules and form modify existing guidance and will apply for coverage offered in 2014.

CMS Publishes Notice on Early Retiree Reinsurance Program

On April 19, 2013, the Federal Register outlined procedures for terminating several processes under the Early Retiree Reinsurance Program (ERRP) in preparation for the Jan. 1, 2014, sunset date. In connection with the Federal Register, CMS issued a press release outlining the last date plan sponsors may update information (Dec. 31, 2013), the deadline for submitting ERRP reimbursement requests (July 31, 2013), the deadline for submitting corrections (July 31, 2013) and the last date to submit an

All Employers Must Begin Using New Form I-9

Federal law requires all U.S. employers to verify the identity and employment eligibility of each employee hired to work in the United States by completing Form I-9. An updated version of Form I-9 is now available for employers to use for employees hired on or after May 7, 2013.

Sixth Circuit Holds That Plan May Amend Terms to Terminate Benefits in Certain Circumstances

On Feb. 15, 2013, the U.S. Court of Appeals for the Sixth Circuit, in Price v. Bd. of Trs. of the Ind. Laborer’s Pension Fund, 707 F.3d 647 (6th Cir. 2013), held that a disability plan may amend its terms to terminate benefits that have already been awarded, so long as the plan in the plan document reserved the right to retroactively amend its terms. In the case, the disability plan was paying disability benefits to a plan participant, but then stopped paying benefits after an amendment to the p

IRS Releases Final Report and FAQs on 401(k) Compliance Check Questionnaire

On March 29, 2013, the IRS released a final report summarizing the results from the 401(k) Compliance Check Questionnaire, a questionnaire previously distributed by the IRS that requested information from 1,200 randomly selected plan sponsors relating to their 401(k) plans.

DOL Provides PowerPoint Presentation on FMLA, Incorporating Final FMLA Rule

On April 11, 2013, the DOL updated its website with a new Microsoft PowerPoint presentation on FMLA.