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New IRS Determination Letter Approval Procedures for 403(b) Plans

The IRS has had a determination letter process for qualified plans under Code section 401(a), like 401(k) and other defined contribution plans, for many years. A favorable IRS determination letter would give the sponsoring...more

Key Considerations When Offering Abortion Coverage Under a Group Health Plan

Not surprisingly, leading up to and in the wake of the U.S. Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, our employee benefits team has been spending a lot of time helping our clients wade through...more

Required Plan Amendment Compliance Tracking Procedure for Individually Designed Retirement Plans

Background (Effective elimination of determination letter process) - In Revenue Procedure 2016-37 the IRS eliminated the determination letter process for individually designed plans for all situations except initial plan...more

ARPA Funding Relief for Single Employer Defined Benefit Pension Plans

On March 11, 2021 President Biden signed the American Rescue Plan Act (Public Law 117-2) ("ARPA"). Among its many provisions, the statute contains "funding relief" for single employer defined benefit pension plans. This...more

IRS Issues Helpful Guidance on How To Terminate a 403(B) Plan

An employer who maintains a 403(b) plan (i.e., a 501(c)(3) tax-exempt corporate employer or a school district or government university) may, for a variety of reasons, decide they wish to terminate their 403(b) plan. For...more

Last Chance to Amend and Restate 403(b) Retirement Plan Documents

Tax-exempt and public-school employers who maintain 403(b) retirement plans for their employees must update their plan documents to comply with applicable legal qualification requirements (as opposed to individual design...more

Expanded Exemption for Religious Employers Regarding Women's Contraceptive Services

The Patient Protection and Affordable Care Act requires non-grandfathered group health plans to cover preventive services at no cost. For women this includes all FDA-approved contraceptive methods, sterilization procedures,...more

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