On November 22, 2021, the Department of Treasury and the IRS issued proposed regulations generally intended to provide Form 1095-B and 1095-C reporting relief. Under the statutory language of the ACA, reporting entities are...more
As we approach the end of 2021, it’s again time for sponsors of 401(a) and 403(b) plans to review their plan documents and plan operations to ensure compliance with increasingly complex qualification requirements. While...more
The IRS recently announced (Notice 2021-61, Nov. 4, 2021) that many of the key pension limits will increase next year – some significantly due to higher inflation. The Social Security Administration and PBGC also recently...more
On October 6, 2021, the IRS released Notice 2021-58 (the “Notice”), which provides yet another round of guidance on the application of extended deadlines for COBRA elections and payments due to COVID-19. This guidance expands...more
The Department of Labor (“DOL”), Department of the Treasury (the “Treasury”), and Pension Benefit Guaranty Corporation (“PBGC”) (collectively, the “Agencies”) recently released a notice of proposed revisions to the Form 5500...more
On July 26, 2021, the IRS released Notice 2021-46 (the “Notice”), which provides new guidance on the 100% COBRA premium subsidies (the “Subsidies”) and the related tax credit under the American Rescue Plan Act of 2021 (March...more
The Department of Labor (“DOL”) recently issued an information letter, DOL Information Letter 06-14-2021 (the “Letter”), addressing the question of whether the ERISA claim regulation requires production of an audio recording...more
Since the American Rescue Plan Act (“ARPA”) was enacted in March 2021, employers and insurers have been diligently familiarizing themselves with the rules for administering the temporary 100% COBRA premium subsidy established...more
On May 18, 2021, the IRS released its highly anticipated guidance on the 100% COBRA premium subsidies (the “Subsidy”) and the related tax credit under the American Rescue Plan Act of 2021 (March 11, 2021) (“ARPA”) in Notice...more
On April 7, 2021, the Department of Labor (“DOL”) released initial guidance regarding the 100% COBRA premium subsidies under the American Rescue Plan Act of 2021 (“ARP”), and also issued model notices that can be used in...more
On February 17th, we posted an alert that the COVID-19 extensions that the DOL and IRS had issued last year as part of their “Joint Notice” were set to expire at midnight on February 28th. For weeks, we have been asking DOL...more
On February 18, 2021, the IRS released Notice 2021-15 (the “Notice”) interpreting section 214 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (the “Act”), enacted as Division EE of the Consolidated...more
As the COVID-19 pandemic began to overwhelm the country last spring, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) became concerned that the disruption caused by the pandemic would create...more
On June 23, the Internal Revenue Service (“IRS”) issued Notice 2020-51, which provides much-needed guidance on how defined contribution plans (including 403(b) and governmental 457(b) plans) and IRAs implement the waiver of...more
6/26/2020
/ Benefit Plan Sponsors ,
CARES Act ,
Defined Contribution Plans ,
Employee Benefits ,
Individual Retirement Account (IRA) ,
IRA Rollovers ,
IRS ,
Required Minimum Distributions ,
Retirement ,
Retirement Plan ,
Retirement Plan Providers ,
SECURE Act
On June 19, 2020, the Internal Revenue Service (“IRS”) issued Notice 2020-50, which provides clarity to plan administrators and participants on coronavirus-related loans and distributions following the passage of the...more
The IRS released two Notices this week related to cafeteria plans and flexible spending arrangements (“FSAs”). Notice 2020-29 provides relief for cafeteria plans in response to the current COVID-19 pandemic, and Notice...more
Plan sponsors, service providers and plan participants have been eagerly awaiting guidance on the new Coronavirus Relief Distribution (CRD) and loan provisions that were added by Section 2202 of the CARES Act. Limited...more
On April 29, 2020, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) issued guidance extending certain deadlines related to retirement, health, and welfare plans in response to the current COVID-19...more
5/6/2020
/ COBRA ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Filing Deadlines ,
Health and Welfare Plans ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Relief Measures ,
U.S. Treasury
Effective March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) brings immediate changes and relief to 401(k) plans, similar to natural disaster relief issued in the past. ...more
This week, the Internal Revenue Service (“IRS”) and Pension Benefit Guaranty Corporation (“PBGC”) both released helpful guidance intended to assist the individuals and organizations affected by the novel coronavirus...more
The last two weeks have seen dramatic changes for communities and businesses as COVID-19 has spread to all parts of the world. Significant disruptions for businesses and individuals have become necessary as we work together...more
In recent years, many defined benefit (“DB”) pension plan sponsors have taken action to limit ongoing coverage and benefit accruals of their DB plans. Over time these plans may have difficulty continuing to satisfy the...more
1/13/2020
/ Benefit Plan Sponsors ,
Best Practices ,
Compensation & Benefits ,
Compliance ,
Defined Benefit Plans ,
Defined Contribution Plans ,
Employee Benefits ,
Employer Liability Issues ,
IRS ,
Minimum Participation Rules ,
New Rules ,
Non-Discrimination Rules ,
Pension Reform ,
Plan Administrators ,
Retirement Plan ,
Retirement Plan Providers ,
SECURE Act ,
U.S. Treasury