EBIA Weekly Newsletter

Ninth Circuit: Participants’ Assignments of Benefits Did Not Authorize Providers’ ERISA Suits


   April 13, 2017

DB Healthcare, LLC v. Blue Cross Blue Shield of Ariz., Inc., 2017 WL 1075050 (9th Cir. 2017) Available at http://cdn.ca9.uscourts.gov/datastore/opinions/2017/03/22/14-16518.pdf The Ninth Circuit has affirmed dismissal of two consolidated cases brought by health care providers seeking payment for medical services pursuant to assignments from patients who were ERISA plan participants. In each case, … Read More


IRS Letter Addresses How Actual Payment Date for Required Minimum Distributions (RMDs) Is Determined


   April 13, 2017

IRS Information Letter 2016-0072 (Sept. 22, 2016) Available at https://www.irs.gov/pub/irs-wd/16-0072.pdf The IRS has released an information letter addressing how the actual payment date for required minimum distributions (RMDs) should be determined. As the letter explains, the tax rules governing RMDs by retirement plans (including 401(k) plans) set deadlines for the payment of each … Read More


What Are the Rules for 401(k) Make-Up Elective Deferrals Under USERRA?


   April 13, 2017

QUESTION: We have several employees who recently returned to their jobs after being on military leave. In addition to making elective deferrals for the current year to our 401(k) plan, some are asking how they can make additional deferrals for the time they were on leave. Can you review for us the USERRA rules for … Read More


DOL Releases Annual Report to Congress on Self-Insured Health Plans


   April 6, 2017

Report to Congress: Annual Report on Self-Insured Group Health Plans (Mar. 2017); Appendix A, Group Health Plans Report: Abstract of 2014 Form 5500 Annual Reports Reflecting Statistical Year Filings (Sept. 2016, v. 1.0); Appendix B, Self-Insured Health Benefit Plans 2017: Based on Filings Through Statistical Year 2014 (Feb. 8, 2017) Report Read More