Insights

On June 20, 2024, the IRS issued Notice 2024-55, which provides guidance on two exceptions to the 10% tax under Code section 72(t)(2) on early retirement plan distributions that were included in the SECURE 2.0 Act. The two exceptions are for emergency personal expense distributions and domestic abuse victim distributions.  The Code defines an emergency personal expense distribution as any distribution made from an applicable eligible retirement plan to an individual for purposes of meeting

On June 24, 2024, the DOL released a report to Congress regarding Interpretive Bulletin 95-1 (the bulletin), which addresses ERISA fiduciary obligations of defined benefit (pension) plan sponsors when they select an annuity provider. The report was issued pursuant to Section 321 of the SECURE 2.0 Act, which directed the DOL to determine whether the bulletin’s guidance required amendment and to assess any risks to plan participants associated with an annuity provider selection.  Pension pla

As we reported in the May 24, 2022, edition of Compliance Corner, payroll withholding of employees’ contributions under Delaware Paid Leave (aka PFML) is scheduled to begin on January 1, 2025, and the benefits will be available to eligible employees starting January 1, 2026. Employers who are interested in electing a private plan option, as well as smaller employers who voluntarily want to opt into the Paid Leave program, can request to do so through the employer portal (“Delaware LaborFir

Gov. Reynolds recently signed several healthcare bills into law.  HB2668 requires health insurance policies issued, delivered, or renewed in Iowa to cover biomarker testing for some cancers and other diseases on or after January 1, 2025.  HF2489 requires that coverage for diagnostic or supplemental breast examinations be no less favorable than coverage providing for screening mammograms. Prior to this bill, participants would have to pay for these additional screenings subject to the

On March 8, 2024, the New Hampshire Insurance Department Commissioner issued Bulletin Docket No INS 24-016-AB to all health insurers. The bulletin recognizes that it is becoming more common for children (insureds 21 years of age and younger) with severe mental illness to receive care from community-based mental health organizations that are funded primarily through contracts with the New Hampshire Department of Health and Human Services. These organizations often do not bill the children’s comm

Recently, the New Hampshire Insurance Department Commissioner issued Bulletin Docket No INS 24-001-AB to all health insurers. The bulletin confirms that the ACA and NH law require blood lead level testing for one- and two-year-old patients without cost-sharing.  Employers with insured coverage in New Hampshire should be aware of this required coverage.  Bulletin Docket No INS 24-001-AB 

No. Both fully insured and self-insured plans must determine the applicable premium for each 12-month COBRA determination period before the beginning of the period and cannot increase the applicable premium during the determination period. In other words, plan sponsors that experience rate changes during a 12-month determination period (e.g., if the policy year and determination period start and end at different times) generally will not be able to pass along rate increases to COBRA participant

Lenders can seize opportunity by incorporating sound home equity protection policies to lessen the negative impact of loan defaults, while continuing to develop growth strategies that generate additional revenue.

On June 13, 2024, the Supreme Court of the United States held in Food and Drug Administration v. Alliance for Hippocratic Medicine that a consortium of doctors and medical organizations opposed to abortion did not have legal standing to challenge the FDA’s actions regarding mifepristone. Mifepristone is an oral abortifacient available to patients in both brand name form (Mifeprex), which the FDA approved in 2000, and generic form, which the FDA approved in 2019. In 2016, the FDA relaxed its ori