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A Better Partnership

Norbert F. Kugele

Partner | Email

  • Grand Rapids

    t. +1.616.752.2186

    f. +1.616.222.2186


Norbert specializes in employee benefits and privacy and information security law. His employee benefits work focuses on health and welfare benefits and the administrative issues associated with them, including COBRA, HIPAA and the Affordable Care Act. Norbert is also a privacy expert who helps organizations understand and comply with state, federal and international privacy and information security laws, including HIPAA, FTC consumer privacy requirements and breach notification laws. He counsels organizations on responding to security breach incidents, develops privacy policies, and counsels companies on the European Union’s General Data Protection Regulations and contracting for cross-border transfers of data. Norbert is a frequent speaker at seminars and author of articles on employee benefits and privacy issues, and is a Certified Information Privacy Professional/US with the International Association of Privacy Professionals.


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  • University of Illinois J.D. 1992 magna cum laude
  • University of Oregon B.A. 1983 Economics


  • 1992, Michigan

Bar Associations

  • American Bar Association
    Health Law Section, Labor and Employment Law Section, Science & Technology Law Section, Taxation Section
  • State Bar of Michigan
    Labor and Employment Law Section, Taxation Section; Information Technology Law Section
  • Grand Rapids Bar Association


  • Helps employers understand and comply with Health Care Reform requirements
  • Works with employers in developing summary plan descriptions and other disclosure documents to effectively communicate benefits and disclosures required under ERISA
  • Conducts nondiscrimination testing for health plans, cafeteria plans, dependent care flexible spending arrangements and group life insurance plans, and advises on plan design strategies to achieve compliance with nondiscrimination requirements
  • Helps employers implement high-deductible health plans, including plans featuring Health Reimbursements Accounts (HRAs) and Health Savings Accounts (HSAs)
  • Negotiates administrative services agreements between plan sponsors and third-party administrators
  • Assists employers and insurers with complex COBRA issues
  • Develops HIPAA privacy and security policies for self-funded health plans
  • Advises insurers on HIPAA privacy and security issues
  • Counsels private and publicly held corporations on executive compensation and severance issues for compliance with Tax Code Sections 409A and 280G
  • Counsels organizations on responding to security breach incidents
  • Represents community hospitals in responding to subpoenas and administrative requests for medical records
  • Develops privacy policies for Internet web sites
  • Counsels companies on European Commission's Directive on Data Protection and U.S.-European Safe Harbor Framework
  • Assists companies with social media policies
  • Serves on American Bar Association committees preparing comments to federal agencies on Health Care Reform and HIPAA regulations

Honors & Awards

  • Lawyer of the Year, Grand Rapids Employee Benefits Law, Best Lawyers', 2019
  • Best Lawyers in America, Employee Benefits (ERISA) Law, 2013-Present
  • 2020 A Lawyer Helps Pro Bono Honor Roll, State Bar of Michigan
  • “Recognized Practitioner” for Employee Benefits and Executive Compensation Law in Michigan, Chambers USA, 2018-19
  • Michigan Super Lawyers, 2010-16
  • AV Preeminent Peer Review Rated, Martindale-Hubbell
  • Leading Lawyers Michigan, 2014
    Advisory Board, 2014
  • Harno Fellow
  • Order of the Coif
  • Note and Comment Editor, University of Illinois Law Review, 1991-92



  • Norbert has authored numerous articles on HIPAA privacy and security issues, structuring of wellness programs, tax code compliance problems for executive compensation arrangements, and electronic delivery of benefit disclosure documents
  • Norbert has also been quoted in articles published in the Grand Rapids Press, the Grand Rapids Business Journal, MIBizWest, the Washington Post and the World Peace Herald

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Professional Affiliations

  • American Health Lawyers Association
  • Grand Rapids Area Chamber of Commerce
    Health Care and Human Resources Committee; Chair of Subcommittee on HSAs (2008)
  • Catholic Lawyers of West Michigan

Community Affiliations

  • Grand Rapids Area Chamber of Commerce
    Health & Human Resources Committee

Speaking Engagements

  • Frequent speaker at in-house, firm-sponsored and professional association seminars on Health Care Reform, HIPAA privacy and security compliance, COBRA administration, executive compensation and ERISA compliance issues
  • "Employer Reporting Requirements for the ACA," Warner Webinar, December 7, 2021
  • "Employee Benefits Two-Part Series on Health and Welfare," Warner Webinar, June 29, 2021
  • "Mid-Year Data Privacy Legal Update," Warner Webinar, May 25, 2021
  • "CCPA Becomes CPRA in 2023: Steps to Take Now," Warner Webinar, February 23, 2021
  • "ACA Reporting Requirements," Warner Webinar, December 9, 2020
  • "Employee Benefits Webinar Series: Part 2 - Health and Welfare Benefits: Recent Developments and Steps to Take Now," Warner Webinar, October 28, 2020
  • "Information Governance 2020," ARMA West Michigan Chapter Webinar, October 21, 2020
  • "Privacy and Information Security Legal Update," Warner Webinar, October 5, 2020
  • "Cyber Liability Webinar," co-sponsored by Warner and Sterling Insurance Group, September 15, 2020
  • "CCPA: A Practical Guide to Compliance," Warner Webinar, June 24, 2020
  • "Health and Welfare Plans: Legal and Strategic Issues," Warner Webinar, June 10, 2020
  • "Data Privacy and Cybersecurity Challenges for Employers Resulting from COVID-19," Warner Webinar, May 28, 2020
  • "The California Consumer Privacy Act Compliance Update," Warner Webinar, October 22, 2019
  • Panelist, "Employee Benefits Panel," Warner 2019 HR Executive Panels, October 1, 2019, Midland, Michigan, and October 16, 2019, Kalamazoo, Michigan
  • “Preparing for the California Consumer Privacy Act (CCPA),” INTERFACE-Grand Rapids, August 28, 2019, Grand Rapids, Michigan
  • "New Health Reimbursement Arrangement Rules Provide An Alternative to Traditional Group Health Plan Coverage," Warner Webinar, July 30, 2019
  • “GDPR Updates on Implementation and Enforcement,” 2019 West Michigan Spring Symposium, May 22, 2019, Grand Rapids, Michigan
  • "Employee Benefits Update" and "Health and Welfare Benefits During Leaves and Layoffs," Warner Human Resources Seminar, May 7, 2019, Grand Rapids, Michigan
  • “Complying with the CCPA” and “Cybersecurity & Privacy: Responding to a Data Breach,” Data Solutions Symposium Spring 2019, Grand Rapids, Michigan, April 17, 2019, and April 23, 2019, Novi, Michigan
  • Presenter, "The California Consumer Privacy Act" Webinar, December 12, 2018
  • Panelist, “Employee Benefits Panel,” Warner 2018 HR Executive Panels, September 19, 2018, Midland, Michigan, and October 12, 2018, Kalamazoo, Michigan
  • "Employee Benefits Update," "What's New with Wellness Programs," and "Benefit Plan Nondiscrimination Testing," Warner Human Resources Seminar, May 3, 2018, Grand Rapids, Michigan
  • "General Data Protection Regulation Panel," Data Solutions Spring Symposium, April 18, 2018, Troy, Michigan
  • "Employee Benefits Legal Update," Employee Benefits Update, January 17, 2018, Troy, Michigan
  • General Data Protection Regulation (GDPR), November 8, 2017, Grand Rapids, Michigan
  • "ACA Report Requirements," Warner Webinar, November 6, 2017
  • Panelist, "Legal and Governance," 2017 Security Symposium, October 25, 2017, Grand Rapids, Michigan
  • "Myth or Truth: Employee Benefits Panel," Warner Labor & Benefits Executive Panels, October 6, 2017, Midland, Michigan
  • "Legal Update and What's on the Horizon," "Keeping Your Wellness Program Compliant," and "Engaging Your Employees" and "Health & Welfare Plans," Warner Human Resources Seminar, May 23, 2017, Grand Rapids, Michigan
  • "2016: Recap and Lessons Learned" and "Invasion of Privacy," Data Solutions Spring Symposium, March 14, 2017, Grand Rapids, Michigan, April 26, 2017, Novi, Michigan 
  • "Understanding the Affordable Care Act Reporting Requirements," Warner Webinar, November 22, 2016
  • "Managing an Evolving Workforce," and "Attracting and Retaining Millennials," Labor & Benefits Executive Panel, October 18, 2016, Kalamazoo, Michigan, October 21, 2016, Traverse City, Michigan, October 25, 2016, Midland, Michigan, November 2, 2016, Novi, Michigan
  • "Legal Update," Detroit Chapter ISCEBS, October 13, 2016, Livonia, Michigan
  • "Legislative Update and Current Trends," "HIPAA Training and Enforcement Update," "High Deductible Health Plans: Consumer-Driven Trends and Pitfalls" and "Health & Welfare Plans," Warner Human Resources Seminar, June 9, 2016, Grand Rapids, Michigan
  • Women In Defense – MI Cybersecurity Event, May 18, 2016, Troy, Michigan
  • "Who's Responsible: A Data Breach Case Study," "Privacy and Security Update," and "Is Your Privacy Policy Up to Date," Data Solutions Spring Symposium, March 11, 2016, Grand Rapids, Michigan, and April 22, 2016, Novi, Michigan
  • "Contracting for Privacy and Security," Data Solutions Fall Symposium, October 23, 2015, Grand Rapids, Michigan
  • Labor & Benefits Executive Panel, Warner Seminar, September 30, 2015, Kalamazoo, Michigan, and October 7, 2015, Midland, Michigan
  • Data Solutions Symposium, Warner Seminar, Southfield, Michigan, June 24, 2015
  • "Legislative Update - Recent Developments in Employee Benefits," "Health and Welfare Panel Discussion" and "Worker Classification - Do You Have the Full Story?," Warner Human Resources Seminar, April 20, 2015, Grand Rapids, Michigan
  • West Michigan American Records Management Association (ARMS) Spring Seminar, Grand Rapids, Michigan, April 16, 2015
  • Data Solutions Symposium, Warner Seminar, Grand Rapids, Michigan, March 20, 2015
  • Employee Benefits/Executive Compensation Panel, Labor and Benefits Executive Panel-Government Enforcement Initiatives, September 23, 2014, Midland, Michigan, and October 23, 2014, Kalamazoo, Michigan
  • "Transitioning to Compliance: The Impact of the Affordable Care Act on Your Family, " Family Office Exchange Webinar, May 14, 2014
  • "Health Care Reform for Small Employers:  Understanding the Affordable Care Act and Health Care Reform for Large Employers:  Understanding the Affordable Care Act, " American Society of Employers, April 29, 2014, Livonia, Michigan
  • "Health Care Reform Update," Warner Human Resources Seminar, April 22, 2014, Grand Rapids, Michigan
  • "Privacy Law Impacts on Records Information Managers," Western Michigan ARMA Chapter Spring Seminar, April 17, 2014, Ada, Michigan
  • "Catching Up with Health Care Reform," Sterling Insurance Group, December 4, 2013, Sterling Heights, Michigan
  • "Catching Up with Health Care Reform," American Society of Employers, November 19, 2013, Livonia, Michigan
  • "The New HIPAA Amendments:  What They Mean for You," KRM RIM Conference, November 13, 2013, Midland, Michigan
  • "Medical Record Disclosures and HIPAA Update," Michigan Osteopathic Association Practice Managers, November 9, 2013, Grand Rapids, Michigan
  • "Catching Up with Health Care Reform," Certified Employee Benefit Specialists, November 5, 2013, Grand Rapids, Michigan
  • "Catching Up with Health Care Reform," Ottawa-Kent Academy of Risk, October 29, 2013, Hudsonville, Michigan
  • “HR and Benefits Executive Panel,” Warner Human Resources Seminar, October 9, 2013, Midland, Michigan and October 15, 2013, Birmingham, Michigan
  • "How does the Historic DOMA Decision Impact Employers?," Grand Rapids Bar Association, October 8, 2013, Grand Rapids, Michigan
  • "How Does the Historic DOMA Decision Impact Employers?," Michigan Chamber of Commerce Webinar, August 28, 2013
  • "What the DOMA Decision means for Employers," The Institute of Continuing Legal Education (ICLE) On-Demand Seminar, July 19, 2013
  • "HR Privacy and Security Strategies," May 21, 2013, Grand Rapids, Michigan
  • "Health Care Reform Update" and "What's New with HIPAA?," Warner Human Resources Seminar, April 29, 2013, Grand Rapids, Michigan
  • "HR Privacy and Security Strategies," March 14, 2013, Birmingham, Michigan
  • "Reporting Costs of Health Insurance on Employee W-2s: New Requirements," Strafford Webinar, December 20, 2012
  • "Recent Legislative Updates for Health and Welfare Plans," West Michigan Chapter of International Society of Certified Employee Benefit Specialists, Nov. 15, 2012, Grand Rapids, Michigan
  • "Recent Developments in HIPAA Privacy and Security," Michigan Osteopathic Practice Manager Program, November 3, 2012, Grand Rapids, Michigan
  • "Health and Welfare Benefits:  An Update," Warner Human Resources Seminar, May 2, 2012, Grand Rapids, Michigan
  • "Are You Ready for W-2 Reporting of the Cost of Employer-Sponsored Health Coverage?," Warner Webinar, January 31, 2012
  • "Employee Benefits Webinar Series: Health Care Reform Webinar," Warner Webinar, September 28, 2011
  • "Does HIPAA Keep You Up At Night?," Warner Seminar, September 20, 2011
  • "What's Next for Health Care Reform?" and "HIPAA: Avoiding Costly Mistakes," Warner Human Resources Seminar, May 25, 2011, Grand Rapids, Michigan
  • "Health Care Reform Webinar: Nondiscrimination Testing and Other Recent Updates," Warner Webinar, November 9, 2010
  • "Health Care Reform Update: Grandfathered Plans," Warner Norcross Webinar, July 14, 2010
  • "Health Care Reform Update," Warner Webinar, April 21 and June 2, 2010
  • "Health Plan Check-Up: The Basics" and "HIPAA Basic Training for Health & Welfare Plan Administrators," Warner Human Resources Seminar, March 23, 2010, Grand Rapids, Michigan
  • "COBRA Subsidy Extension: What This Means For You," Warner Webinar, January 27, 2010
  • "The New HIPAA Amendments: What It Means for You," program cosponsored with Apec Applied Security in Grand Rapids, Michigan, on May 19, 2009
  • "The New COBRA Subsidy Requirements," program on March 26, 2009, Grand Rapids, Michigan
  • "New COBRA Requirements: Economic Stimulus Program Requires Quick Action," program on March 3, 2009, Grand Rapids, Michigan; and on March 5, 2009, Southfield, Michigan 
  • "Red Flag Compliance: Protecting Yourself and Your Patients From Identity Theft," program on March 18, 2009, Grand Rapids, Michigan
  • "Time to Shape Up Your Cafeteria Plan" and "Hot Fringe Benefits Issues, " Warner Human Resources Seminar, September 11, 2008, Grand Rapids, Michigan
  • "Does Your Cafeteria Plan Need Updating?," January 9, 2008, Grand Rapids, Michigan

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