Juliana Reno
Juliana's practice covers all facets of employee health and welfare benefit plans, and all phases of a plan's life cycle — creation, operation, amendment, correction, and termination. She regularly handles matters related to the Employee Retirement Income Security Act (ERISA), Health Insurance Portability and Accountability Act (HIPAA), Consolidated Omnibus Budget Reconciliation Act (COBRA), and the Affordable Care Act (ACA). She is particularly experienced in addressing issues in health benefits — not only major medical plans, but also health savings accounts (HSAs), health reimbursement accounts (HRAs), and flexible spending accounts (FSAs). Juliana has helped numerous clients through Department of Labor (DOL) audits and has responded to many Internal Revenue Service (IRS) notices seeking ACA employer penalties.
Juliana's client base spans employers, multiemployer plans, and service providers. She counsels corporate teams, hospitals, restaurants, technology companies, staffing agencies, nonprofits and associations, professional employer organizations (PEOs), home health agencies, and more. She also advises businesses that provide services to employers and plans — insurers, third-party administrators, and wellness companies.
Juliana makes sure her clients capitalize on opportunities tied to ever-changing employee benefits laws. Her work includes not only medical, dental, and vision plans, but also cafeteria plans, life and disability plans, and qualified retirement plans. A recovering litigator, Juliana also advises clients regarding disputes involving benefits claims, retiree medical cutbacks, breaches of fiduciary duty, and claims for equitable relief.
Experience
Representative Matters
- Advising employers regarding the ACA, including how to balance premium costs and employer penalty risks, provide ACA-compliant coverage, follow ACA reporting requirements, and respond to IRS penalty notices
- Providing advice to corporate clients with complex organizational charts regarding variances in health plan eligibility and benefits rules, calculation of COBRA premiums, and use of benefit-plan surpluses
- Designing fertility, surrogacy, and adoption programs to increase equity in overall benefits structure
- Assisting clients through inquiries, investigations, and audits by the IRS, DOL, and Department of Health and Human Services (HHS)
- Advising clients on the full range of federal and state laws that impact voluntary employees' beneficiary associations (VEBAs), multiple employer welfare arrangements (MEWAs), and association health plans (AHPs)
- Designing HIPAA privacy compliance programs, including drafting policies and procedures, preparing and negotiating business associate agreements, and training privacy workers
- Integrating and coordinating company-wide leave programs and continuation-of-benefits policies with welfare benefit plans and change-of-status rules
- Providing issuers and third-party administrators ongoing representation concerning all manner of ERISA compliance, including assistance with new product development, administrative services agreements, notices, plan documents, benefits booklets, and summary plan descriptions (SPDs)
- Providing guidance concerning Qualified Small Employer Health Reimbursement Arrangements (QSHERAs), Individual Coverage Health Reimbursement Arrangements (ICHRAs), and other account-based health plans
Insights
Credentials
Education
- J.D. magna cum laude Creighton University School of Law 1993
- B.A. cum laude Yale University 1987
- Distinction in the Major (Religious Studies)
Bar Admissions
- Nebraska
- New Jersey
- New York
Clerk Experience
- Honorable C. Thomas White Nebraska Supreme Court
- Honorable C. Arlen Beam U.S. Court of Appeals for the Eighth Circuit
Professional Memberships and Activities
- Member, ABA Joint Committee on Employee Benefits
- Former adjunct professor, Creighton University School of Law and John Marshall Law School, teaching employee benefits courses
Recognition
- Legal 500, Employee Benefits and Executive Compensation, 2015, 2021