Author: Lisa Dursey

IRS Announces 2024 HSA Contribution Limits, HDHP Minimum Deductibles and HDHP Maximum Out-of-Pocket Amounts

The IRS has announced 2024 HSA and HDHP limits as follows:

Annual HSA contribution limitation. For calendar year 2024, the annual limitation on deductions for HSA contributions under § 223(b)(2)(A) for an individual with self-only coverage under a high deductible health plan is $4,150 (up from $3,850 in 2023), and the annual limitation on deductions for HSA contributions under § 223(b)(2)(B) for an individual with family coverage under a high deductible health plan is $8,300 (up from $7,750 in 2023).

High deductible health plans. For calendar year 2024, a “high deductible health plan” is defined under § 223(c)(2)(A) as a health plan with an annual deductible that is not less than $1,600 for self-only coverage or $3,200 for family coverage (up from $1,500 and $3,000 in 2023), and with respect to which the annual out-of-pocket expenses (deductibles, co-payments, and other amounts, but not premiums) do not exceed $8,050 for self-only coverage or $16,100 for family coverage (up from $7,500 and $15,000 in 2023).

Rev. Proc 2023-23

Impact of SECURE Act 2.0 on Employers

The Consolidated Appropriations Act, 2023, a 4,155-page omnibus bill, was approved by Congress in its final form on December 23, 2022, and is expected to be signed by President Joe Biden before government funding runs out on December 30, 2022. The text of the SECURE 2.0 of 2022 is called “Division T” of the Appropriations Act and can be found on pages 2046 through 2404 of the bill. The Senate Finance Committee has issued a summary of the SECURE Act 2.0.

The SECURE Act 2.0 contains several important rules for employers operating retirement plans. Many of these rules mandate that employers make operational changes to their retirement plans, and complying with these regulatory changes will require careful administration by all employers. Following is a non-comprehensive overview of some of the Act’s most important provisions for employers.

Increased RMD Age

A beneficiary of qualified retirement plans and regular IRAs is currently required to start taking distributions from his or her account by April 1 following the year he or she attains age 72. Effective on January 1, 2023, the Act raises the age for required minimum distributions (RMDs) as follows:

  • To age 73 for a person who reaches age 72 after December 31, 2022 and age 73 before January 1, 2033; and
    • To age 75 for a person who reaches age 74 after December 31, 2032.

Higher Catch-Up Limits for Plan Participants Ages 60 to 63

Participants over age 50 who make elective deferrals to 401(k), 403(b), and SIMPLE plans are permitted to make “catch-up” contributions in addition to their regular contributions. The current maximum amounts for 2023 are $7,500 for 401(k) and 403(b) plans and $3,500 for SIMPLE plans. These amounts are adjusted for inflation.

Starting in 2025, plan participants can make an additional catch-up contribution after attaining 60 and prior to attaining age 64. For 403(b) and 401(k) plans, the amount is the greater of $10,000 or 50% more than the regular catch-up amount. For SIMPLE plans, the amount is the greater of $5,000 or 50% more than the regular catch-up amount.

“Rothification” Requirement for Catch-Up Contributions

Starting in 2024, catch-up contributions to 401(k) and 403(b) plans must be treated as Roth contributions. There is an exception for employees who made $145,000 (as adjusted for inflation) or less in the previous year.

Matching of Student Loan Repayments

Employers have long wondered how to help employees who have large student loan burdens. The SECURE Act 2.0 provides an answer: it permits an employer to make matching contributions under a 401(k) plan, 403(b) plan, or SIMPLE IRA with respect to “qualified student loan payments.” A qualified student loan payment is broadly defined as any indebtedness incurred by the employee solely to pay qualified higher education expenses of the employee.

Non-Monetary Incentives for Employees

The Act permits employers to offer de minimis financial incentives, not paid for with plan assets, such as low-dollar gift cards, to boost employee participation in workplace retirement plans. Such de minimis financial incentives would have previously been prohibited.

Expanded Automatic Enrollment

Effective for plan years beginning after 2024, newly adopted 401(k) and 403(b) plans will be required to automatically enroll participants upon becoming eligible to make elective deferrals. The initial automatic enrollment percentage must be at least 3% of compensation and must be increased annually until it is at least 10%. Employees will be able to opt out of making these elective deferrals.

Exceptions to Early Withdrawal Penalty

The SECURE Act 2.0 adds a variety of additional exceptions to the 10% penalty for pre-age 59 1/2 withdrawals from IRAs and retirement plans.

Effective in 2023, the following types of distributions are exempt from the penalty: (1) Distributions of up to $22,000 for individuals affected by a federally declared disaster that occurred on or after January 26, 2021; (2) Distributions to individuals with a terminal illness; and (3) Corrective distributions made to highly compensated employees from 401(k) and 403(b) plans as a result of the plan’s failure to pass certain nondiscrimination tests.

Effective in 2024, the following types of distributions are exempt from the penalty: (1) Distributions of up to $1,000 for unforeseeable or immediate emergency expenses; and (2) Distributions to victims of domestic abuse, up to the lesser of $10,000 or 50% of the account balance. Both of these distributions have the option to allow repayment to the plan within 3 years.

Effective 3 years after the date of the enactment of the SECURE Act 2.0, distributions of up to $2,500 per year for the payment of premiums for certain long term care insurance contracts.

Please contact us with any questions about how to implement the changes required by the SECURE Act 2.0.

IRS Announces COLA Adjusted Retirement Plan Limitations for 2023

The Internal Revenue Service today released Notice 2022-55 announcing cost of living adjustments affecting dollar limitations for pension plans and other retirement-related items for tax year 2023.

Highlights Affecting Plan Sponsors of Qualified Plans for 2023

  • The contribution limit for employees who participate in 401(k), 403(b), most 457 plans, and the federal government’s Thrift Savings Plan is increased from $20,500 to $22,500.
  • The catch-up contribution limit for employees aged 50 and over who participate in 401(k), 403(b), most 457 plans and the federal government’s Thrift Savings Plan increased from $6,500 to $7,500.
  • The limitation under Section 408(p)(2)(E) regarding SIMPLE retirement accounts remains is increased from $14,000 to $15,500.
  • The limit on annual contributions to an IRA increased from $6,000 to $6,500. The additional catch-up contribution limit for individuals aged 50 and over is not subject to an annual cost-of-living adjustment and remains $1,000.
  • The limitation on the annual benefit under a defined benefit plan under Section 415(b)(1)(A) is increased from $245,000 to $265,000.
  • The limitation for defined contribution plans under Section 415(c)(1)(A) is increased for 2022 from $61,000 to $66,000.
  • The annual compensation limit under Sections 401(a)(17), 404(l), 408(k)(3)(C), and 408(k)(6)(D)(ii) is increased from $305,000 to $330,000.
  • The dollar limitation under Section 416(i)(1)(A)(i) concerning the definition of “key employee” in a top-heavy plan is increased from $200,000 to $215,000.
  • The dollar amount under Section 409(o)(1)(C)(ii) for determining the maximum account balance in an employee stock ownership plan subject to a five year distribution period is increased from $1,230,000 to $1,330,000, while the dollar amount used to determine the lengthening of the five year distribution period is increased from $245,000 to $265,000.
  • The limitation used in the definition of highly compensated employee under Section 414(q)(1)(B) is increased from $135,000 to $150,000.

The IRS previously updated Health Savings Account limits for 2023. See our post here.

The following chart summarizes various significant benefit Plan limits for 2021 through 2023:

Type of Limitation202320222021
415 Defined Benefit Plans$265,000$245,000$230,000
415 Defined Contribution Plans$66,000$61,000$58,000
Defined Contribution Elective Deferrals$22,500$20,500$19,500
Defined Contribution Catch-Up Deferrals$7,500$6,500$6,500
SIMPLE Employee Deferrals$15,500$14,000$13,500
SIMPLE Catch-Up Deferrals$3,500$3,000$3,000
Annual Compensation Limit$330,000$305,000$290,000
SEP Minimum Compensation$750$650$650
SEP Annual Compensation Limit$330,000$305,000$290,000
Highly Compensated$150,000$135,000$130,000
Key Employee (Officer)$215,000$200,000$185,000
Income Subject To Social Security Tax  (FICA)$160,200$147,000$142,800
Social Security (FICA) Tax For ER & EE (each pays)6.20%6.20%6.20%
Social Security (Med. HI) Tax For ERs & EEs (each pays)1.45%1.45%1.45%
SECA (FICA Portion) for Self-Employed12.40%12.40%12.40%
SECA (Med. HI Portion) For Self-Employed2.90%2.90%2.90%
IRA Contribution$6,500$6,000$6,000
IRA Catch-Up Contribution$1,000$1,000$1,000
HSA Max. Contributions Single/Family Coverage$3,850/ $7,750$3,650/ $7,300$3,600/ $7,200
HSA Catchup Contributions$1,000$1,000$1,000
HSA Min. Annual Deductible Single/Family$1,500/
$3,000		$1,400/ $2,800$1,400/ $2,800
HSA Max. Out Of Pocket Single/Family$7,500/
$14,100		$7,050/ $14,100$7,000/ $14,000

IRS Announces 2023 HSA Contribution Limits, HDHP Minimum Deductibles and HDHP Maximum Out-of-Pocket Amounts

The IRS has announced 2023 HSA and HDHP limits as follows:

Annual HSA contribution limitation. For calendar year 2023, the annual limitation on deductions for HSA contributions under § 223(b)(2)(A) for an individual with self-only coverage under a high deductible health plan is $3,850 (up from $3,650 in 2022), and the annual limitation on deductions for HSA contributions under § 223(b)(2)(B) for an individual with family coverage under a high deductible health plan is $7,750 (up from $7,300 in 2022).

High deductible health plans. For calendar year 2023, a “high deductible health plan” is defined under § 223(c)(2)(A) as a health plan with an annual deductible that is not less than $1,500 for self-only coverage or $3,000 for family coverage (up from $1,400 and $2,800 in 2022), and with respect to which the annual out-of-pocket expenses (deductibles, co-payments, and other amounts, but not premiums) do not exceed $7,500 for self-only coverage or $15,000 for family coverage (up from $7,050 and $14,100 in 2022).

Rev. Proc 2022-24

IRS Announces COLA Adjusted Retirement Plan Limitations for 2022

The Internal Revenue Service today released Notice 2021-61 announcing cost of living adjustments affecting dollar limitations for pension plans and other retirement-related items for tax year 2022.

Highlights Affecting Plan Sponsors of Qualified Plans for 2022

  • The contribution limit for employees who participate in 401(k), 403(b), most 457 plans, and the federal government’s Thrift Savings Plan is increased from $19,500 to $20,500.
  • The catch-up contribution limit for employees aged 50 and over who participate in 401(k), 403(b), most 457 plans and the federal government’s Thrift Savings Plan remains unchanged at $6,500.
  • The limitation under Section 408(p)(2)(E) regarding SIMPLE retirement accounts remains is increased from $13,500 to $14,000.
  • The limit on annual contributions to an IRA remains unchanged at $6,000. The additional catch-up contribution limit for individuals aged 50 and over is not subject to an annual cost-of-living adjustment and remains $1,000.
  • The limitation on the annual benefit under a defined benefit plan under Section 415(b)(1)(A) is increased from $230,000 to $245,000.
  • The limitation for defined contribution plans under Section 415(c)(1)(A) is increased for 2022 from $58,000 to $61,000.
  • The annual compensation limit under Sections 401(a)(17), 404(l), 408(k)(3)(C), and 408(k)(6)(D)(ii) is increased from $290,000 to $305,000.
  • The dollar limitation under Section 416(i)(1)(A)(i) concerning the definition of “key employee” in a top-heavy plan is increased from $185,000 to $200,000.
  • The dollar amount under Section 409(o)(1)(C)(ii) for determining the maximum account balance in an employee stock ownership plan subject to a five year distribution period is increased from $1,165,000 to $1,230,000, while the dollar amount used to determine the lengthening of the five year distribution period is increased from $230,000 to $245,000.
  • The limitation used in the definition of highly compensated employee under Section 414(q)(1)(B) is increased from $130,000 to $135,000.

The IRS previously updated Health Savings Account limits for 2021. See our post here.

The following chart summarizes various significant benefit Plan limits for 2020 through 2022:

Type of Limitation202220212020
415 Defined Benefit Plans$245,000$230,000$230,000
415 Defined Contribution Plans$61,000$58,000$57,000
Defined Contribution Elective Deferrals$20,500$19,500$19,500
Defined Contribution Catch-Up Deferrals$6,500$6,500$6,500
SIMPLE Employee Deferrals$14,000$13,500$13,500
SIMPLE Catch-Up Deferrals$3,000$3,000$3,000
Annual Compensation Limit$305,000$290,000$285,000
SEP Minimum Compensation$650$650$600
SEP Annual Compensation Limit$305,000$290,000$285,000
Highly Compensated$135,000$130,000$130,000
Key Employee (Officer)$200,000$185,000$185,000
Income Subject To Social Security Tax  (FICA)$147,000$142,800$137,700
Social Security (FICA) Tax For ER & EE (each pays)6.20%6.20%6.20%
Social Security (Med. HI) Tax For ERs & EEs (each pays)1.45%1.45%1.45%
SECA (FICA Portion) for Self-Employed12.40%12.40%12.40%
SECA (Med. HI Portion) For Self-Employed2.90%2.90%2.90%
IRA Contribution$6,000$6,000$6,000
IRA Catch-Up Contribution$1,000$1,000$1,000
HSA Max. Contributions Single/Family Coverage$3,650/ $7,300$3,600/ $7,200$3,550/ $7,100
HSA Catchup Contributions$1,000$1,000$1,000
HSA Min. Annual Deductible Single/Family$1,400/ $2,800$1,400/ $2,800$1,400/ $2,800
HSA Max. Out Of Pocket Single/Family$7,050/ $14,100$7,000/ $14,000$6,900/ $13,800

IRS Announces 2022 HSA Contribution Limits, HDHP Minimum Deductibles and HDHP Maximum Out-of-Pocket Amounts

The IRS has announced 2022 HSA and HDHP limits as follows:

Annual HSA contribution limitation. For calendar year 2022, the annual limitation on deductions for HSA contributions under § 223(b)(2)(A) for an individual with self-only coverage under a high deductible health plan is $3,650 (up from $3,600 in 2021), and the annual limitation on deductions for HSA contributions under § 223(b)(2)(B) for an individual with family coverage under a high deductible health plan is $7,300 (up from $7,200 in 2021).

High deductible health plans. For calendar year 2022, a “high deductible health plan” is defined under § 223(c)(2)(A) as a health plan with an annual deductible that is not less than $1,400 for self-only coverage or $2,800 for family coverage (unchanged from 2021), and with respect to which the annual out-of-pocket expenses (deductibles, co-payments, and other amounts, but not premiums) do not exceed $7,050 for self-only coverage or $14,100 for family coverage (up from $7,000 and $14,000 in 2021).

Rev. Proc 2021-25

COVID Stimulus Bill provides Free COBRA Coverage

On March 11, 2021, the American Rescue Plan Act of 2021 (“ARPA”) was signed into law by President Biden. The ARPA includes several significant health, pension funding, executive compensation and other tax changes. Notably, the ARPA provides temporary COBRA and Affordable Care Act subsidies intended to help people maintain health insurance during the pandemic.

Six months of free cobra

The ARPA provides employers a 100% COBRA subsidy for “assistance eligible individuals” where the qualifying event is an involuntary termination of employment or reduction in hours. An “assistance eligible individual” is any COBRA qualified beneficiary who loses group health coverage on account of a covered employee’s reduction in hours of employment or involuntary termination of employment. The subsidy applies not only to federal COBRA coverage, but also to state law programs that provide comparable continuation coverage.

For a period of up to six months, an “assistance eligible individual” is treated as having paid their COBRA coverage in full if the individual timely elects COBRA coverage. This means the person to whom the premiums are usually paid cannot collect the premium from the assistance eligible individual. One hundred percent of the premium is subsidized by the federal government via a tax credit mechanism.

Tax Credit

The tax credit works by allowing the “person to whom premiums are payable” (the employer for a self-insured plan and the insurer for a fully insured plan) to claim a tax credit for the COBRA premium assistance that was provided to an assistance eligible individual for any period of COBRA coverage during the subsidy period of April through September 2021.

This credit applies against that entity’s liability for the Medicare Hospital Insurance (“HI”) tax (i.e., the 1.45% Medicare payroll tax). It also applies as a credit against any applicable similar tax under the Railroad Retirement Tax Act (“RRTA”) imposed on compensation paid to railroad employees and representatives. The amount of the credit generally cannot exceed the HI tax (or RRTA tax), reduced by any credits otherwise allowed under other COVID-19 relief acts (the Coronavirus Aid, Relief, and Economic Security Act or the Families First Coronavirus Response Act).

The ARPA provides that the IRS could allow such credits to be advanced, and the IRS may issue further guidance about the mechanics of such an advance.

DURATION OF SUBSIDY PERIOD

The ARPA COBRA subsidy period is between April 1, 2021 and September 30, 2021. Importantly, the ARPA subsidy is available only to those whose initial COBRA period ends (or would have ended if COBRA had been elected/did not lapse) either during or after this six-month period.  The subsidy does not lengthen the COBRA period.

OPTIONAL New Election Right

Employers are permitted to allow individuals who are eligible for ARPA COBRA relief to change elections to other plan options that have the same or lower cost premiums. This election right is optional and employers are not required to offer it.

Notification Requirement

Plan administrators must notify eligible employees by May 31, 2021 (60 days after April 1, 2021), and the notice must include a description of the extended election options as well as certain plan information. The U.S. Department of Labor is required to issue model COBRA notices addressing the subsidy, and we expect the government agencies to issue guidance on various issues related to the subsidy in the coming weeks.

Please reach out to your ERISA Benefits Law contact if you have any questions about the implementation of this COBRA relief.

American Rescue Plan Act of 2021, H.R. 1319

Presence Not Required – IRS Extends Remote Signature Procedures for Qualified Plans

The IRS has extended temporary relief allowing plan representatives to witness participant elections or spousal waivers via videoconference until June 30, 2021. 

The IRS initially provided relief from the physical presence requirement from January 1, 2020 through December 31, 2020 in IRS Notice 2020-42 in response to the COVID-19 related social distancing restrictions. On December 22, 2020, the IRS extended that relief through June 30, 2020 through IRS Notice 2021-03.

The relief provides that participant elections required to be witnessed by a plan representative or notary public, including spousal consent, may be satisfied using alternative procedures that do not require physical presence. For a participant election witnessed by a notary public, the physical presence requirement is deemed satisfied with remote notarization using live audio-video technology that satisfies certain requirements. For a participant or spousal election witnessed by a plan representative, the physical presence requirement is deemed satisfied if an audio-video system is used that satisfies the following requirements:

  1. The individual signing the election presents a valid photo ID to the plan representative during the videoconference (transmitting the ID before or after the videoconference is not good enough);
  2. The video conference is live and allows direct interaction between the participant and plan representative;
  3. The individual faxes or electronically transmits a legible copy of the signed document to the plan representative on the same day it is signed; and
  4. After receiving the signed document, the plan representative acknowledges that the signature has been witnessed by the plan representative and transmits the signed document, including the acknowledgement, back to the individual using an electronic medium the individual can easily access.

Notice 2021-03

Employee Benefits Relief in the Year-End COVID-19 Stimulus Legislation

The Consolidated Appropriations Act, 2021 (H.R. 133) (the “Act”) was passed by both houses of Congress on December 21, 2020, and signed into law by the President on December 27, 2020. The Act is an incredible 5,593 pages long and contains both an omnibus spending bill to fund the government through September 30, 2021 and a COVID-19 stimulus package that provides approximately $900 billion in emergency relief to individuals and businesses.

The Act contains numerous provisions that impact employee benefit plans. The principal takeaways from the Act that plan sponsors must consider are summarized below. In contrast to the length of the Act itself, this alert is intended to provide a high level summary. Please reach out to us if you have specific questions about the Act.

Health and Welfare Plan Related Provisions

This is the largest health care legislative package since the Affordable Care Act and the Act includes almost a dozen new patient protections with quickly approaching effective dates, which will result in significant new regulation being issued in 2021.

FSA Flexibility

The Act provides for significant additional flexibility for both health care flexible spending arrangements (“FSA”) and dependent care FSAs. These provisions are optional, not required, and employers will need to amend their plans to provide the new rights, if they choose to offer them.

Carryover. Any unused funds in FSAs from a plan year ending in 2020 or 2021 may be carried over and used at any time in the next plan year. These carryovers will be allowed under rules similar to the existing carryover rules for health FSAs (but without the dollar limit on carryovers).

Grace Periods. FSAs with grace periods may extend those grace periods to up 12 months for plan years ending in 2020 or 2021. Normally, grace periods have a maximum 2 ½-month period.

Post-Termination Reimbursement. If an employee terminates participation during calendar year 2020 or 2021, FSAs may also reimburse for otherwise eligible expenses incurred through the end of that year (plus any grace period).

Dependent Care Post-Age 13 Coverage. For dependent care FSAs, if a dependent became too old to have their care expenses reimbursed (age 13) due to the pandemic, any unused funds may be used for the remainder of the plan year in which they aged out. Further, if any funds remain unused at that time, those funds can be used until the child turns 14.

Prospective Changes Permitted. For plan years ending in 2021, employees may prospectively change their FSA contributions without incurring a permitted election change event.

“No Surprise” Medical Billing Provisions

Under a section titled the “No Surprises Act,” the Act includes several provisions to regulate surprise medical billing from certain non network providers, air ambulances and for emergency services. These provisions concern bills from out-of-network providers requiring more money from the patient after the health plan has paid its part. This can happen in an emergency setting or where a patient goes into an in-network hospital, but is treated there by an out-of-network provider.

Generally, the Act provides that individuals covered by a group health plan or individual/group health insurance receiving non-emergency services at a network facility cannot be balance billed by a non-network provider, unless the non-network provider provides notice to the individual and the individual consents. An exception exists for “ancillary services”, such as anesthesiology, pathology, and radiology, and the Act also fleshes out associated details, such as payment timelines and dispute resolution processes.

The agencies are required to begin finalizing implementing regulations regarding the methodology for making payments by July 1, 2021, with the rest to come by December 31, 2021. These provisions become effective January 1, 2022.

These rules replace the current Affordable Care Act rules governing the payment of emergency services and apply to both grandfathered and non-grandfathered plans.

Additional Health Plan Provisions

ID Card Information. ID cards for group health plans (physical or electronic) must include, in clear writing, the deductible, out-of-pocket limits, and consumer assistance information.

Continuity of Care. Patients undergoing treatment for a serious and complex condition, who are pregnant, receiving inpatient care, scheduled for non-elective surgery or terminally ill must be notified if their provider leaves the network and given the opportunity to continue care (at an in-network rate) for 90 days.

Cost Comparison Tools. Plans and carriers will be required to offer cost comparison tools (via phone or the internet) starting with plan years beginning on or after January 1, 2022.

Gag Clauses Prohibited. “Gag” clauses will be prohibited. These clauses prevent health plans from sharing provider-specific reimbursements and information. Prohibiting these clauses facilitates the creation of the cost-comparison tools.

Provider Directories. Group health plans must update provider directories at least every 90 days and establish a system to respond to inquiries about the network status of a provider within one business day.

Mental Health Parity. Plans will be required to analyze the nonquantitative treatment limitations that they apply to mental health and substance use disorder benefits to show that the limitations are comparable to those that are used for medical/surgical benefits.

Retirement Plan Related Provisions

Partial Plan Terminations. The Act provides for temporary relief from the 100% vesting requirement for partial plan terminations caused by employee turnover under Code section 411(d)(3) if the turnover is due to COVID-19. A qualified plan will not incur a partial termination during any plan year which includes the period beginning on March 13, 2020, and ending on March 31, 2021, if the number of active participants covered by the plan on March 31, 2021, is at least 80% of the number of active participants covered by the plan on March 13, 2020.

Coronavirus-Related Distributions. The Act extends the COVID-19 in-service distribution relief under the CARES Act to money purchase pension plans.

Disaster Relief (Not Including COVID). The Act provides special disaster related distribution and loan rules (similar to prior natural disaster relief, including a distribution right, increase in loan limits, loan suspensions, etc.) for FEMA declared disasters (other than COVID-19) from January 1, 2020 through 60 days after enactment of the Act. 

Consolidated Appropriations Act, 2021

Webinar: The Must-Do’s and Common Mistakes of Employee Benefit Planning

Lisa Dursey joins Stephanie Rising of The Rising Effect in a 15-minute webinar discussing the must-do’s and common mistakes of administering employee benefit plans. This webinar provides a concise primer on how to structure and correctly administer your plans.

Stephanie starts the webinar by explaining the importance of your new-hire process, and then dives more deeply into traditional and lifestyle benefits that attract and retain talented employees. Lisa then outlines the common mistakes that are made in administering those benefits, and how to correct them.

Contact ERISA Benefits Law to discuss your benefit plan administration or for help resolving any plan errors. Please note that in addition to general benefits advice, ERISA Benefits Law attorneys are well versed in designing sick leave policies for COVID-19.