Megan Mardy
Subscribe to Megan Mardy's PostsMegan Mardy advises companies on a wide variety of health and welfare and retirement benefits issues. She has extensive experience with the Affordable Care Act, the Health Insurance Portability and Accountability Act (HIPAA), Consolidated Omnibus Budget Reconciliation Act (COBRA), the Internal Revenue Code and other federal laws affecting group health and retirement plans. Read Megan Mardy's full bio.
DOL Relaxes Deadlines for ERISA-Governed Group Health Plans
By Jacob Mattinson and Megan Mardy on May 13, 2020
Posted In Benefit Controversies, Employee Benefits, Employment, Health and Welfare Plans
The US Department of Labor, in conjunction with the Internal Revenue Service and US Department of the Treasury, issued guidance and deadline extensions applicable to ERISA-governed group health and welfare plans. The guidance provides relief for plan sponsors, plan administrators and plan participants that may be struggling to comply with applicable deadlines and requirements in...
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Department of Labor Updates COBRA FAQs and Model Notices
By Jacob Mattinson and Megan Mardy on May 7, 2020
Posted In Employee Benefits, Health and Welfare Plans
On May 1, 2020, the Department of Labor (DOL) issued updated Frequently Asked Questions and revised model notices under the Consolidated Omnibus Budget Reconciliation Act (COBRA). COBRA is a federal law that permits individuals to continue group health plan coverage for a limited period of time following certain events, such as a termination of employment,...
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Families First Coronavirus Response Act Mandates Employer-Provided Coverage for COVID-19 Testing
By Erin Steele, Jacob Mattinson and Megan Mardy on Mar 23, 2020
Posted In Employee Benefits, Health and Welfare Plans
As part of the Families First Coronavirus Response Act (the “Act”), Congress eliminated patient cost-sharing for Coronavirus (COVID-19) diagnostic testing and testing-related services provided under any employer-sponsored group health plan. This impacts all employer plans, insured and self-funded, of all sizes. The provisions are effective as of March 18 and will continue on a temporary...
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Fla. Class Actions Show Why Correct COBRA Notices Matter
By Julie H. McConnell and Megan Mardy on Nov 14, 2019
Posted In Benefit Controversies, Employee Benefits, Employment, Health and Welfare Plans
In Florida’s federal courts, there has been an epidemic of class actions alleging that employers failed to provide technically proper notice of the right to continued healthcare coverage under the Consolidated Omnibus Budget Reconciliation Act. A dozen such lawsuits have been filed (each by the same law firm) with mirror image allegations. These cases illustrate...
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A New Day for the HRA
By Jacob Mattinson, Megan Mardy and McDermott Will & Emery on Jul 30, 2019
Posted In Employee Benefits, Health and Welfare Plans
The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other account-based group health plans to qualify as limited excepted benefits. These rules are generally effective for plan years beginning on or after...
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IRS Announces 2020 Limits for Health Savings Accounts and High-Deductible Health Plans
By Jacob Mattinson and Megan Mardy on May 30, 2019
Posted In Employee Benefits, Health and Welfare Plans
The Internal Revenue Service (IRS) recently announced cost-of-living adjustments to the applicable dollar limits for health savings accounts and high-deductible health plans for 2020. Nearly all of the dollar limits currently in effect for 2019 will change for 2020. See a comparison of the applicable dollar limits for HSAs and HDHPs for 2019 and 2020....
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DOL Offers Interim Relief for Employers’ Association Health Plans
By Megan Mardy and McDermott Will & Emery on May 7, 2019
Posted In Employee Benefits, Health and Welfare Plans
Last week, the Department of Labor (DOL) responded to the district court decision striking down the final regulations expanding the ability for a group of unrelated employers to form an organization in order to offer health care to its members. The DOL’s statement setting forth policy positions regarding association health plans (AHPs) indicated its intent...
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Court Puts Association Health Plans in Limbo
By Jacob Mattinson and Megan Mardy on Apr 9, 2019
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans
On March 28, a District of Columbia federal court agreed with a New York-led challenge by a group of 11 states and the District of Columbia and found that the Department of Labor’s (DOL) 2018 association health plan (AHP) rule (the Final Rule): Is contrary to the Employee Retirement Income Security Act of 1974 (ERISA)’s...
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ERISA Health Plan Fiduciaries Defeat DOL’s Excessive Fee Claims
By Erin Steele, Megan Mardy and Richard J. Pearl on Mar 26, 2019
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans
In one of the first ERISA cases to address claims against fiduciaries for excessive health plan fees, the court entered judgment in favor of the defendants on all counts. The decision addresses health plan fiduciary standards for reviewing plan fees and expenses. Access the full article.
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ERISA Plan Documents Must State Procedures for Authorizing a Representative under a Plan
By Jacob Mattinson and Megan Mardy on Mar 19, 2019
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans, Retirement Plans
In an Information Letter dated February 27, 2019, the Department of Labor (DOL) clarified that an ERISA plan must include any procedures for designating authorized representatives in the plan’s claims procedure and summary plan description (SPD) or in a separate document that accompanies the SPD. In response to a request by a patient advocate and...
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