Supreme Court Decision – Change in Administrative Power 

A Supreme Court decision released last week overturned a 40-year precedent known as the Chevron Doctrine. Under the doctrine, when a federal statute was silent or ambiguous, courts were expected to defer to federal agency interpretations (e.g., for health and welfare benefits, regulations and guidance interpreting federal statutes are generally issued by the DOL, IRS and HHS). Going forward, courts have the power to interpret federal statutes that are silent and ambiguous and are not required to defer to federal agency interpretations. The court case was not benefits-related and does not have any immediate impact on any benefit-related regulations or guidance issued by federal agencies. Employers should continue to follow the current interpretations of agencies such as the DOL, IRS and HHS. However, such interpretations are perhaps more likely to be successfully challenged in the courts over upcoming months and years, potentially creating some confusion and instability for employers who currently rely heavily on federal agency interpretations of various requirements under ERISA, COBRA, HIPAA, ACA, tax law and more. For now, employers should stay the course. We’ll see how this plays out over time as agency interpretations specific to health and welfare benefit compliance are challenged in the courts. 

The Supreme Court’s opinion in Lopez Bright Enterprises v. Raimondo can be found here –