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When Are Disability Benefit Programs Exempt From ERISA?

When Are Disability Benefit Programs Exempt From ERISA?

QUESTION: I am reviewing our company’s employee benefit programs and confirming that they are treated appropriately for ERISA compliance purposes. Our disability program provides income-replacement benefits to employees who are unable to work because of illness...

Are HSA Contribution Programs Ever Subject to ERISA?

Are HSA Contribution Programs Ever Subject to ERISA?

QUESTION: We are planning to add an HDHP and to make company contributions to employees’ HSAs. We have been told that an HSA contribution program—unlike the HDHP coverage—would not be subject to ERISA. Is that always true, or are there circumstances in which...

Are PCOR Fees Plan Expenses?

Are PCOR Fees Plan Expenses?

QUESTION: Our company sponsors a calendar-year self-insured major medical plan subject to ERISA. Are we permitted to treat Patient-Centered Outcomes Research (PCOR) fees as plan expenses? ANSWER: The DOL has indicated that PCOR fees generally are not permissible...

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Understanding DCAP Reimbursement Rules: Can You Pay Your Child for After-School Care?

Understanding DCAP Reimbursement Rules: Can You Pay Your Child for After-School Care?

Can Our DCAP Reimburse Expenses for the Care of a Child Who Will Turn 13 Later in the Plan Year? ...

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