One of the most common employer mistakes, especially in non-union environments, is the failure to recognize that employees have a legally protected right to protest or criticize working conditions. That protection resides in the National Labor Relations Act (the “Act”), regardless of whether employees are union represented. Recently, a non-union […]
Labor & Employment Law Update
Trump Administration Rules Expand the Use of Health Reimbursement Arrangements
On June 13, 2019, the Trump Administration finalized regulations to expand Health Reimbursement Arrangements (“HRAs”), providing employers with more options for offering health insurance coverage to employees. The final regulations now authorize employers to provide employees with tax-preferred funds to pay for the cost of health insurance coverage purchased in […]
The Clock Is Ticking: What Employers Should Know to Prepare for EEO-1 Pay Data Submissions
Despite administrative conflicts surrounding the newly revived EEO-1 Component 2 pay data requirements, employers should now begin preparing their compensation data for submission to the Equal Employment Opportunity Commission (“EEOC”). As previously reported here, in April of this year, a federal judge set September 30, 2019 as the deadline for […]
IRS Expands Determination Letter Program
In a May 1, 2019, Revenue Procedure, the IRS expanded the determination letter program to reach statutory hybrid plans and plan mergers. As background, in 2017, the IRS significantly narrowed the application of its determination letter program for individually designed qualified plans. Prior to 2017, individually designed retirement plans were […]
EEO-1 Pay Data Roller Coaster
In a whirlwind few weeks, the fate of the EEO-1 Pay Data requirement (referred to as “Component 2”) was finally decided…or was it? As a quick refresher, the EEO-1 survey must be filed annually by private employers with 100 or more employees, and by federal contractors with 50 or more […]

