Letters to Agencies

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ERIC Comments on Proposed Regulations Relating to Hardship Distribution Provisions

ERIC submitted comments to the Internal Revenue Service on proposed regulations relating to hardship distribution provisions for 401(k) plans… More

ERIC Submits Comments on North Dakota’s Reinsurance Program

On behalf of The ERISA Industry Committee (ERIC), thank you for accepting input from interested stakeholders as you explore ways to stabilize North Dakota’s individual health insurance market through a reinsurance program… More

ERIC Comments on North Dakota Telemedicine Bill

Today, ERIC submitted comments on North Dakota Senate Bill 2094, which would require most telemedicine visits to be performed using both audio and video communication technology… More

ERIC Submits Comments on North Dakota’s Proposed Telemedicine Legislation

On behalf of The ERISA Industry Committee (ERIC), thank you for accepting input from interested stakeholders as you consider the proposed legislation, Senate Bill 2094, regarding telemedicine… More

protected content ERIC Letter to IRS—Comments requested by 1-14-19 on Hardship Distribution Rules

Members please provide comments on this draft letter to the IRS addressing hardship distributions by Monday, January 14… More

ERIC Encourages IRS to Provide Guidance on Student Loan Relief

ERIC worked with a coalition of companies and business groups to encourage the IRS to provide guidance that all employers could use when considering student loan relief in their retirement plans… More

protected content Missing Participants Comment Letter - Review

Click here to review a draft letter to the Department of Labor regarding Missing Participants. The purpose of this letter is to provide the DOL with additional information on what we would like to see in any guidance that the DOL issues in the near future… More

protected content ERIC: Wellness Rule Vacated, House Moves ACA Tax Delay, Final HRA Comments, and More!

Today we will discuss: (1) EEOC signals the end of their current ADA & GINA wellness rules, (2) House moves tax vehicle with ACA tax delays, (3) ERIC files comment letter on proposed HRA rule, (4) Judge says ACA is unconstitutional, but leaves it in place (5) ERIC comments on Administration’s 1332 waiver speed-dating proposal (6) Air ambulance – ERIC needs volunteers for a federal advisory board, (7) Ding, dong, HPID is dead, (8) Surprise billing – ERIC develops joint principles with employer, consumer groups… More

ERIC Submits Comments on Proposal to Expand Health Reimbursement Arrangements

ERIC submitted comments on the Trump Administration’s proposal to expand and facilitate access to Health Reimbursement Arrangements (HRAs) and other account-based plans… More

ERIC Submits Comments to CMS on 1332 Waivers

The ERISA Industry Committee is pleased to submit these comments in response to the Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services (HHS), and the Department of the Treasury (Treasury) guidance related to section 1332 of the Patient Protection and Affordable Care Act (ACA) and its implementing regulations, published in the Federal Register on October 24, 2018… More

ERIC’s Comment Letter on Albany County Paid Sick Leave

The ERISA Industry Committee (“ERIC”) applauds your efforts to provide paid sick time to employees working in Albany County. Your proposed local law to provide access to paid sick time (“Local Law”), while well-intentioned, without small revisions will increase the compliance and financial burdens on large employers that already provide paid leave to employees in the county, the state, and other jurisdictions… More

protected content Illinois Secure Choice Update

In a prior email I mentioned that the Illinois Secure Choice Retirement Plan was sending emails to large companies requesting that the company either commence the enrollment process into the Secure Choice Plan or report that the company provides a retirement plan to employees and is exempt from the Secure Choice mandate… More

ERIC Offers IRS a Helping Hand on Student Loan Debt

ERIC today sent the Internal Revenue Service (IRS) a letter regarding retirement savings programs for individuals repaying student loans. In the letter, ERIC praised the IRS for issuing Private Letter Ruling-131066-17, which permits the 401(k) plan sponsor that requested the PLR to contribute to the company’s 401(k) plan on behalf of plan participants who pay down student loan debt but do not necessarily contribute to the company’s 401(k) plan … More

ERIC Submits Comments on Proposed New York City Retirement Program

ERIC submitted comments with the New York City Council regarding proposed bill Int. 0888-2018, that would establish a retirement savings program for private-sector employees. ERIC supports proposals and programs run by states and localities designed to promote and facilitate retirement saving by those employed by an employer that does not provide a retirement plan, but has concerns about how the proposed program overlaps and connects with the Employee Retirement Income Security Act of 1974 (ERISA), the federal law that already governs the administration of private-sector retirement plans … More

ERIC Offers Guidance on Missing Plan Participants

ERIC sent a letter to Assistant Secretary of Labor Preston Rutledge encouraging the Department of Labor (DOL) to focus its efforts on developing guidance related to the challenge of employers locating missing retirement plan participants. The letter also asks that until guidance is provided, the DOL should stop issuing letters that allege an employer has committed a breach of fiduciary duty with respect to the practices utilized to locate missing retirement plan participants… More

ERIC Submits Comments to HHS on the President’s “American Patients First” Blueprint

Today, ERIC submitted comments to the Department of Health and Human Services (HHS) in response to its Request for Information related to the HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs… More

ERIC Works to Bring Clarity to Mental Health Parity Laws

ERIC today filed comments with the Departments of Health and Human Services, Labor, and Treasury on mental health parity compliance. The comments focused on the time needed for plan sponsors to prepare for and come into compliance with new requirements, more stakeholder input on the processes, definitions, and interpretations by the agencies, and flexibility by the agencies in enforcing the MHPAEA rules… More

ERIC Submits Letter to HRC on its Corporate Equality Index

We are writing about some of the new criteria added to the 2019 Corporate Equality Index (CEI) announced by the Human Rights Campaign (HRC)… More

ERIC Sends Comment Letter on the Determination Letter Program to the IRS

The ERISA Industry Committee (“ERIC”) and the In-House Benefits Counsel Network (the “IBCN”) are pleased to respond to the request of the U.S. Treasury Department and the Internal Revenue Service (collectively, the “Agencies”) for comments regarding Notice 2018-24, relating to their “Request for Comments on Scope of Determination Letter Program for Individually Designed Plans during Calendar Year 2019” (the “Notice”)… More

Employer Groups Call for Suspension of Tax Assessments and Repeal of the Employer Mandate

The ERISA Industry Committee (ERIC) joined a number of employer trade associations to call upon the U.S. Department of the Treasury, the Department of Health and Human Services, and the Internal Revenue Service to end the illegal enforcement of the Affordable Care Act’s employer mandate… More

protected content Alert: ERIC Submits Comments on Louisiana State Innovation Waiver Application

Today, ERIC submitted comments on Louisiana’s State Innovation Waiver Application for a reinsurance program… More

ERIC Submits Comments on Ways to Stabilize Louisiana’s Individual Health Insurance Market

On behalf of The ERISA Industry Committee (ERIC), thank you for accepting input from interested stakeholders as you explore ways to stabilize Louisiana’s individual health insurance market through a reinsurance program… More

protected content Alert: ERIC Submits Comments on DC Paid Leave Rules

This morning, ERIC submitted comments to the District of Columbia's Department of Employment Services on its proposed regulations for implementing the Universal Paid Leave Amendment Act of 2016 (UPLA)… More

ERIC Submits Comments on DC Paid Leave Rulemaking

The ERISA Industry Committee (ERIC) appreciates the opportunity to comment on the Department of Employment Services’ (DOES) proposed rules implementing the Universal Paid Leave Amendment Act of 2016 (UPLA), D.C. Law 21-264; D.C. Official Code § 32-541.01 et seq… More

ERIC Supports Pennsylvania Telehealth Legislation

The ERISA Industry Committee (ERIC) submitted testimony to the Pennsylvania State Senate in support of Senate Bill 780 (S. 780)… More

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019