Teal Trujillo
Subscribe to Teal Trujillo's PostsTeal Trujillo focuses her practice on employee benefits and executive compensation matters for public and private companies. She regularly leads due diligence and advises on liability related to retirement plans, health and welfare plans and executive compensation in stock purchase and asset purchase transactions. Read Teal Trujillo's full bio.
IRS Opines on the Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policies
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Aug 10, 2023
Posted In Employee Benefits, Health and Welfare Plans
In light of recent Internal Revenue Service (IRS) guidance, employers should carefully examine any supplemental health plan, program or arrangement (which may or may not claim to leverage fixed indemnity insurance) that promises substantial payroll tax savings. In a legal advice memorandum, the IRS’s Office of Chief Counsel addressed and rejected the claimed tax treatment...
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Fixing the ACA’s Family Glitch
By Alden Bianchi and Teal Trujillo on Jul 13, 2023
Posted In Employee Benefits, Health and Welfare Plans
The “family glitch” was a regulatory oddity of the Affordable Care Act (ACA). It required the affordability of an employer-sponsored health plan to be determined based solely on the cost of the plan to an individual employee, disregarding the costs to add family members to a plan. This resulted in many families being ineligible for...
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IRS Issues Reminder that Claims Under Health and Dependent Care FSAs Must Be Substantiated
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Jun 1, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Internal Revenue Service (IRS) recently issued a Chief Counsel Advice memorandum to remind sponsors of health and dependent care flexible spending arrangements (FSAs) about their responsibility to adequately substantiate claims in order to receive favorable tax treatment under Section 125 of the Internal Revenue Code (the Code). The IRS emphasizes that the standards for...
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Preparing for the End of the COVID-19 Emergency: Deadline Tolling
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on May 18, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April 10, 2023, President Biden signed a resolution moving up the end of the NE to April 10, 2023 (the PHE ended...
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Tri-Agencies Address Preventive Services Coverage in the Wake of Braidwood
By Sarah Raaii, Jacob Mattinson, Alden Bianchi and Teal Trujillo on May 5, 2023
Posted In Employee Benefits, Health and Welfare Plans
The US Departments of Labor, Health and Human Services, and the Treasury (the Departments) have released a series of Frequently Asked Questions (FAQs) in response to Braidwood Mgmt. Inc. v. Becerra, a recent case that invalidated a portion of the Affordable Care Act (ACA) preventive services mandate. The FAQs aim to address inquiries from stakeholders,...
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Preparing for the End of the COVID-19 Emergency: High-Deductible Health Plans and Health Savings Accounts
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on May 3, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Biden administration originally announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our prior article for more information). Although the end date of the NE was subsequently advanced to April 10, 2023, by Congressional resolution, the US Departments of Labor, Health and Human...
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Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Apr 5, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On March 29, 2023, the US Departments of Labor, Health and Human Services, and Treasury (the Departments) issued a set of Frequently Asked...
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Mental Health Parity, Quantitative Treatment Limitations, Employee Assistance Plans and the End of the COVID-19 Emergency
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Mar 29, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). Among other things: The NE and the PHE modified the rules governing financial requirements and quantitative treatment limitations under the Mental Health Parity...
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Telehealth and the End of the COVID-19 Emergency
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Mar 22, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Biden administration has announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our prior article for more information). In response to the COVID-19 pandemic, lawmakers and agencies made legislative and regulatory changes to expand access to telehealth services for individuals. This article explores...
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Coverage of COVID-19 Vaccines and the End of the COVID-19 Emergency
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Mar 15, 2023
Posted In Employee Benefits, Health and Welfare Plans
Since the Biden administration announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023, a topic of great debate has been the requirement and the coverage of COVID-19 vaccines. As of March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act has...
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