The majority of all multiemployer employee benefit plans are managed by a Board of Trustees, comprised of an equal number of members from the applicable Union(s) and representatives from Employers who employee union members. Such Trustees are charged with significant responsibilities that range from overseeing the delegated administrator of their employee benefit plans, monitoring the collection of plan contributions to eligibility for and approval of all types of plan...
Continue reading…
Group Health Plan’s Residential Treatment Exclusion Violates Mental Health Parity Requirements
The Mental Health Parity Act (“MHPA”) was enacted in 1996. The principal goal of MHPA was to bring parity to the treatment of mental health disorders by imposing the same aggregate lifetime and annual dollar limits for mental health benefits as for medical and surgical benefits. In Munnelly v. Fordham Univ. Faculty and Admin. HMO Ins. Plan, 2018 WL 1628839 (S.D.N.Y. 2018), the application of this goal was tested...
Continue reading…
Internal Revenue Service Requests Comments on Expansion of Determination Letter Program for Individually Designed Retirement Plans
The Internal Revenue Service (“IRS”) has asked for comments on whether it should expand the determination letter program for individually designed plans for 2019. Currently, determination letter applications for individually designed tax-qualified retirement plans (including 401(k) plans) may be submitted only for initial plan qualification—i.e., submissions by plans that have never received a determination letter—and for terminating plans. The guidance establishing those rules anticipated that the IRS would...
Continue reading…