In a recent blog post we discussed the new disability claims procedure rules scheduled to go into effect on January 1, 2018.

Earlier this year, as part of the administration’s direction to evaluate existing regulations to make them less burdensome, the Department of Labor (DOL) opened a comment period (through December 11, 2017) on whether the new disability claims procedure rule should be modified, rescinded or retained and raised the possibility of a delay.

Based on the mixed comments received thus far on the need for the delay, the DOL decided to push the implementation of the new disability claim procedure rules for 90 days (through April 1, 2018).  This will allow additional time to undertake a full and fair review of the disability benefit claims procedure and determine what, if any, changes are required to avoid imposing unnecessary cost and adverse consequences.

Author

Janel Brynda has been part of the Baker McKenzie Employment & Compensation Practice since 2000, with a focus on executive compensation and employee benefits. Janel regularly advises US and multinational companies on a wide range of traditional employee benefit issues including the design, implementation, operation and termination of tax- qualified retirement plans and health and welfare benefit plans. She advises clients with all aspects of regulatory compliance associated with employee benefits plans. She also helps clients with plan audits and correcting plan defects through DOL and IRS correction programs. She has experience assisting clients with negotiating settlements with the IRS and DOL. She also advises clients on executive compensation arrangements and nonqualified deferred compensation programs. Janel also has extensive experience assisting clients with employee benefit issues raised in multijurisdictional mergers and acquisitions, spin-offs, reorganizations and other corporate transactions. She also assists companies with multi-jurisdictional employee benefits issues including transition and integration issues which result from corporate transactions.