In late July, the Department of Labor proposed new regulations that would extend the “notice-and-access” electronic disclosure model that the DOL finalized in 2020 for retirement plans to group health plans. The proposed rule closely tracks the current notice-and-access model for retirement plan disclosures, but with some modifications for health plans, as explained below.
Comments on the proposed rule are due by September 21, 2026. The following are important points about the proposal:
Proposal is limited to group health plans. The new safe harbor would be available only for “group health plan” disclosures. Disability, life, severance, and other welfare plan disclosures remain outside the safe harbor. This may result in inefficiency, as health plan disclosures are often bundled with other welfare plan disclosures (which won’t be covered by the new group health plan safe harbor). The DOL requested comment on whether to expand the safe harbor to other welfare plans.
Opt-out regime: an… Read the complete article here...
© 2026 Proskauer Rose LLP.
