Sarah Bassler Millar counsels public, private and nonprofit companies and organizations on managing and administering health and welfare benefits, retirement plans and non-qualified plans. She is Chair of the firm’s Employee Benefits and Executive Compensation Group.
Sarah guides clients on the design, implementation and operation of benefit plans to ensure consistency with plan terms and compliance with ERISA and tax code requirements. She also advises on fiduciary governance matters, including current best practices and the implications of the prohibited transaction rules. When counseling clients, Sarah focuses on identifying solutions that not only effectively manage identified compliance issues, but also take into account the client’s employee recruitment and retention goals.
As leader of the practice group’s Health Care Reform Team, Sarah assists clients across industry sectors develop strategies related to compliance with the Affordable Care Act. Her leadership and extensive experience provide a framework for advising clients on overall administrative compliance, documentation, and implementation.
Among the issues that Sarah counsels on are assessing the impact of employer shared responsibility provisions and implementing effective and compliant wellness programs. Sarah is regularly invited by clients and other organizations to speak and present on health care reform as it relates to employee benefits.
Sarah has been an active member of the Notre Dame Club of Chicago since 2002 and served on the Club’s board of directors from July 2004 – June 2014, including as Club President from July 2012 – June 2013. The ND Club of Chicago serves the 17,000+ alumni living in the Chicagoland area through a variety of community service, networking, continuing education and social events. The mission of the Club includes raising funds for the ND Club of Chicago Scholarship Foundation and for the sponsorship of Summer Service Learning Projects in Chicago. The Foundation currently provides need-based scholarship assistance to over 70 local students attending Notre Dame.
Sarah also serves as a lector at St. Gertrude’s parish and is a regular volunteer at her children’s elementary school in the Edgewater neighborhood of Chicago.
- Counseled clients across industry sectors on strategic responses to the 2014 employer shared responsibility (“pay or play”) mandate, including application of the rules regarding offering coverage to “substantially all” (95 percent of) full-time employees; implementing recordkeeping systems for tracking hours of service under the new IRS rules; and evaluating employment classification and benefit eligibility options for part-time and non-traditional (e.g., temporary, intermittent, per diem) positions.
- Conducted training sessions for HR managers and supervisors, as well as business associates, regarding the HIPAA Privacy and Security Rules.
- Counseled clients regarding the employee benefit implications of mergers, acquisitions, spin-offs, and other corporate transactions and drafted related documentation, including corporate and committee resolutions, retirement and severance plans, and retention arrangements.
- Assisted a variety of clients with benefit plan integration issues following corporate acquisitions, including assessment of strategic options, maintaining “protected” benefits, ensuring compliance with nondiscrimination rules and how/when to take advantage of controlled group transition rules, and streamlining benefit plan administration.
- Assisted several Fortune 500 companies with responses to DOL audits of their retirement plans and health and tax-exempt health systems.
- Assisted several Fortune 500 companies with preparations for IRS audit of their retirement plans.
- Audited a Fortune 500 pharmaceutical company’s classification of contingent workers and prepared related compliance and training materials for managers, supervisors and staff.
- Conducted comprehensive benefit plan operational reviews for a health care system to identify areas of potential liability for noncompliance and implemented a comprehensive risk mitigation strategic plan.
- Assisted faith-based organizations with evaluating how “church plan” status applies to their organizations, assessing the pros and cons of church plan status and implementing an effective governance process for those plains maintained as a church plan.
- Obtained an individual prohibited transaction exemption on behalf of a retirement plan sponsor.
- Reviewed retirement plan operational errors and assisted in their correction, including through the Employee Plans Compliance Resolution System (EPCRS).
Thomas J. White Scholar, University of Notre Dame Law School
Awards Methodology (www.drinkerbiddle.com/content/awards)
- University of Notre Dame Law School, J.D., 2001
- University of Notre Dame, B.A., 1997
- American Bar Association
- Notre Dame Club of Chicago