Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.
Just when you thought the confusing COVID-19 ERISA deadline extensions were behind you, the Biden-Harris Administration asks you to reconsider. Recap – In response to the COVID-19 National Emergency, DOL and Treasury issued guidance requiring benefit plans to extend certain ERISA deadlines related to COBRA continuation coverage, HIPAA special enrollment, and benefit claims and appeals, […]
SECURE 2.0 brought significant changes to retirement planning and distributions, including updating the Required Minimum Distribution (RMD) requirements. As background, RMDs are the minimum amounts that individuals who attain their “required beginning date” must withdraw from their retirement accounts each year. SECURE 2.0 introduced several changes to the rules on RMDs including the following: 1. […]
Effective December 29, 2022, Section 305 of SECURE 2.0 expands the ability for plan sponsors to self-correct certain plan failures under the Employee Plans Compliance Resolution System (“EPCRS”). Section 305 of SECURE 2.0 generally permits the self-correction of certain “eligible inadvertent failures” under EPCRS, including certain plan loan failures, provided that: (1) the failure is […]
For more information regarding the principal requirements under the CAA that apply to employer-sponsored group health plans, see our updated CAA Chart.
As described in Part 4 of our 2022 end of year plan sponsor “to do” list, on October 26, 2022, the Securities and Exchange Commission published the final clawback rules under the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). The clawback rules were published in the Federal Register on November 28, 2022 and become effective […]
Institutional Shareholder Services Inc. (“ISS”), a leading proxy advisory firm, uses a proprietary “Equity Plan Scorecard” approach to evaluate public company equity compensation plans. For 2023, ISS has updated its Equity Plan Scorecard and the corresponding Frequently Asked Questions (“FAQs”). A full link to the ISS guidance can be found here. Although we are well […]
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The Biden Administration recently announced its plan to end both the National Emergency and Public Health Emergency for COVID-19 (together, the “COVID-19 Emergencies”) on May 11, 2023. The end of the COVID-19 Emergencies will trigger (immediately or within specified timeframes) the end of various COVID-19 requirements and related relief for group health plans. As further […]
On January 30, 2023, the Departments of Health and Human Services, Treasury, and Labor (collectively “the Departments”) issued proposed rules entitled “Coverage of Certain Preventive Services under the Affordable Care Act” (the “Proposed Rules”). The Proposed Rules reflect the Departments’ continuing efforts to ensure that women have access to contraceptive care without cost sharing through […]
