March 11
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IRS Notice 2020-15
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HDHPs may cover testing and treatment for COVID-19 before satisfaction of the deductible or with a deductible below the HDHP minimum
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High-Deductible Health Plans can Cover Coronavirus Costs
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March 13
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Declaration of National Emergency/Stafford Act Declarations of Emergency for All U.S. States, Territories, and Possessions
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Stafford Act declarations permit hardship withdrawals from 401(k) and 403(b) plans for the duration of the emergency
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March 27
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CARES Act – Retirement Plans
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– Authorizes time-limited relief for 401(k), 403(b), and governmental 457(b) plan participants directly affected by COVID-19
– Special distributions up to $100,000, with tax relief
– Plan loans up to $100,000 or 100% of account balance
– Postponed plan loan payments
– Waives 2020 RMDs from defined contribution plans
– Defined benefit plan sponsors may postpone 2020 required minimum contributions
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With CARES Act, Congress Provides Retirement Plan Relief and Group Health Plan Changes
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March 27
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CARES Act – Group Health Plans
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– Mandates coverage of certain medical care to prevent or mitigate COVID-19 and of certain in vitro diagnostic services without cost-sharing or preauthorization
– HDHPs may cover telehealth and other remote care before satisfaction of the deductible or with a deductible below the HDHP minimum
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With CARES Act, Congress Provides Retirement Plan Relief and Group Health Plan Changes
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April 10
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PBGC Disaster Relief Announcement
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Extended deadlines for premium payments and filings due on or after April 1 to July 15
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April 28
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DOL Disaster Relief Notice 2020-01
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– Relief for retirement plan fiduciaries who cannot meet certain ERISA requirements during the Outbreak Period due to COVID-19
– Good faith failures to timely furnish ERISA notices, disclosures, and other documents, if furnished as soon as administratively practicable
– Good faith failures to timely remit participant contributions and loan payments to a plan, if remitted as soon as administratively practicable
– Guidance related to granting CARES Act distributions and loans
– Guidance on blackout notices, Form 5500 and Form M-1 filing relief, and other general compliance guidance on ERISA fiduciary responsibilities during COVID-19
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May 4
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DOL/IRS Final Rule: Extension of Certain Timeframes for Employee Benefit Plans, Participants and Beneficiaries Affected by the COVID-19 Outbreak
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Extends certain health plan time frames affecting special enrollment and COBRA coverage, as well as claims and appeal deadlines for all ERISA plans, to the end of the Outbreak Period
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IRS and DOL Extend Certain Health & Welfare Benefit Plan-Related Deadlines
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May 12
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IRS Notice 2020-29
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– Cafeteria plans may permit mid-year changes to employer-sponsored health coverage, health FSAs, and dependent care assistance programs (including dependent care FSAs) without a status change event
– Claims period for health FSAs and dependent care assistance programs extended
– Clarifies and expands relief allowing HDHPs to cover expenses related to COVID-19 and telehealth services retroactive to January 1, 2020
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IRS Relaxes Rules for Cafeteria Plans and Clarifies Relief for High Deductible Health Plans
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May 12
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IRS Notice 2020-33
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– Limit on carry-over amounts in a health FSA increased to $550
– Clarifies timing for health plan reimbursements
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IRS Relaxes Rules for Cafeteria Plans and Clarifies Relief for High Deductible Health Plans
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May 27
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DOL Final Rule: Default Electronic Disclosure by Employee Pension Benefit Plans under ERISA
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New alternative safe harbor for electronic delivery of required disclosures under ERISA Title I
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DOL E-Disclosure Rule Recognizes our New (Digital) Reality
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June 3
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IRS Notice 2020-42
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Temporary relief from the physical presence requirement for witnessing certain plan elections during 2020
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June 19
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IRS Notice 2020-50
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Expanded relief and guidance for retirement plan distributions and loans under the CARES Act
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IRS Issues New Guidance on Cares Act Retirement Plan Distributions and Loans
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June 23
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IRS Notice 2020-51
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Guidance for waiver of 2020 RMDs under the CARES Act, including eligibility for rollover into a retirement plan or IRA if voluntarily received or received before passage of the CARES Act
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June 23
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IRS Notice 2020-52
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Temporary relief related to certain mid-year changes to safe harbor 401(k) or 401(m) plans that reduce or suspend safe harbor contributions
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July 20
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PBGC COVID-19-Related Single-Employer Plan Sponsors and Administrators Questions and Answers
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Guidance for postponement of required minimum contributions under the CARES Act
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July 30
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IRS Coronavirus-related Relief for Retirement Plans and IRAs – Questions and Answers, Q15
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In general, participants terminated due to the COVID-19 pandemic and rehired in 2020 will not cause a partial plan termination
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Employee Layoffs May Vest Retirement Plan Benefits
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August 6
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IRS Notice 2020-61
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Guidance on the special rules relating to funding of single-employer defined benefit plans and related benefit limitations under the CARES Act
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