Posts Categorized: Welfare Benefits


in Welfare Benefits

For those of you who have enjoyed the health and welfare blog posts, I wanted to let you know of a major announcement coming soon.  We are currently in the process of updating and expanding the blog site.  When that is complete, we will be sending an announcement regarding our expanded content and new contributing authors.  In addition, you can look forward to a new topic coming in March.  We will be reviewing the employee benefit aspects of a weekly television show, and showing how employee benefits can even touch cinematic lives.  Which television show you ask?  Well, for now, I will… Continue Reading

Supreme Court Upholds ERISA Limitation Periods

in Court Cases, Health Benefits, Retiree Benefits, Welfare Benefits

The U.S. Supreme Court in a unanimous decision has ruled that contractual limitations periods in ERISA plans are enforceable.  The only two qualifications that such limitation periods must satisfy is that they must be reasonable in length and not prohibited by another applicable statute.  In the instant case, the Supreme Court dealt with a disability plan that contained a 3-year limitations period.  The 3-year limitations period began on the day the person became disabled, not on the day that the final appeal was denied.  The court said that beginning the limitations period on the date of disability was appropriate.  ERISA’s… Continue Reading

DOL Issues Additional SBC Guidance

in Welfare Benefits

To date, I think the SBC requirement has the most DOL frequently asked questions. In fact, some of the SBC FAQs are even drafted similar to the PPACA statute itself, because later FAQs amend and revise earlier FAQs, making them even harder to read. However, today the most recent SBC guidance is simple. In a single FAQ, DOL makes it clear that retiree health plans, and Medicare advantage plans sponsored by employers, do not have an SBC requirement. A link to the FAQ can be accessed here:

KT Submits Comments Concerning the PCOR Fee

in Welfare Benefits

Today, the health and welfare team submitted comments to the IRS regarding the PCOR Trust Fee proposed regulations. These comments request that the IRS exempt stand-alone HRAs from the PCOR fee, if the HRA funds are being used to purchase otherwise exempt benefits. The comments can be viewed here: Comments with IRS to Exempt Stand-Alone HRAs from the PCOR Trust Fee