With this year fast coming to a close, there may be notices, plan amendments and/or administrative changes that should be completed as the new year approaches.
This year, the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act of 2010 ("Affordable Care Act") has been the impetus for many of the changes affecting benefit plans. While the tri-agencies of Treasury, Labor and Health & Human Services (the "Departments") have issued a flurry of regulations and model notices, many issues are still in need of further clarification. In the interim, the Departments have indicated that employers should still take steps toward good faith compliance with the law. For this reason, to the extent not otherwise undertaken, employers should review the requirements of the law and determine whether notices and/or amendments in their benefit plan are required....
In addition to the Affordable Care Act requirements, the following chart provides a brief summary of other year end items affecting group health plans, cafeteria plans (including FSA, HRA and HSAs) qualified retirement plans and executive compensation.
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