Midyear Premium Increases and Cafeteria Plan Rules
COVID-19-Related Guidance Allows Employees to Revise 2020 Health Insurance Elections
COVID-19 Impact for Health & Welfare Plans (Troutman Sanders and Pepper Hamilton COVID-19 Issues for Employers Podcast Series)
PODCAST: Williams Mullen's Benefits Companion - COVID-19 Edition; New Opportunities for Health Flexible Spending Arrangements and Cafeteria Plans
Compliance Issues Associated with Section 125 Plans
On April 28, 2023, the IRS Office of Chief Counsel issued Chief Counsel Advice Memorandum 202317020 (CCA Memo), with an important reminder to employers who provide health and dependent care flexible spending arrangements...more
On April 28, 2023, the Internal Revenue Service (“IRS”) Office of Chief Counsel issued a Chief Counsel Advice (“CCA”) explaining the requirements for claim substantiation for health and dependent care flexible spending...more
Most employers allow employees covered by the employer-sponsored group health and welfare plans to pay their share of the cost through pre-tax payroll deductions. In order to do this the employer must maintain a written...more
In the first article of this Health FSA series, we covered how to determine if an employer’s Health FSA is discriminatory. In the second and final article of this series, we’ll cover what employers should consider if their...more
As the year draws to a close, it is helpful for employers to pause to evaluate employee benefit plan amendment deadlines and other crucial fourth quarter considerations, including:...more
The Internal Revenue Service (IRS) has published Notice 2021-26 to provide answers regarding the taxability of benefits received in 2021 and 2022 under a dependent care assistance program (DCAP) that permits carryovers or...more
Yesterday the IRS released Notice 2021-26, which clarifies that if eligible dependent care benefits would have been excluded from income if used during either the prior tax year (2020 or 2021), these benefits remain...more
The American Rescue Plan Act of 2021 (“ARPA”) increases the dependent care flexible spending arrangement (“DCFSA”) annual limit from $5,000 to $10,500. The increase only applies to the 2021 calendar year. Employers are not...more
The Consolidated Appropriations Act, 2021 (CAA) contained temporary relief measures aimed at addressing unused contributions to health flexible spending accounts (FSA) and dependent care assistance programs (DCAP). On...more
On February 18, 2021, the IRS issued Notice 2021-15, which provides guidance with regard to a number of provisions of the temporary changes to the rules related to the operation of health and dependent care flexible spending...more
Much of the previous relief that had been granted to cafeteria plans during the COVID-19 pandemic was set to expire after 2020. In late December, though, Congress passed the Consolidated Appropriations Act, 2021 (CAA), which...more
In Notice 2021-15, the IRS provides many answers to questions regarding the temporary special rules introduced as part of the Consolidated Appropriations Act, 2021 (CAA) for health flexible spending accounts (health FSAs) and...more
On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (FSAs) and dependent care assistance programs (DCAPs) that were included in the...more
On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (“FSAs”), and dependent care assistance programs (“DCAPs”) that were included in...more
You might recall that in December 2020, Congress passed the year-end funding bill known as the Consolidated Appropriations Act, 2021 (CAA), which contained provisions that provide significant flexibility for flexible spending...more
On February 18, 2021, the Internal Revenue Service (IRS) issued clarifying guidance on the temporary special rules for health flexible spending arrangements (FSAs) and dependent care assistance programs (DCAPs) under Internal...more
Thanks to the Consolidated Appropriations Act, 2021 (the “Act”), employers with health flexible spending accounts (“HFSAs”) and dependent care flexible spending accounts (“DFSAs”) may adopt temporary liberalized rules to help...more
On December 27, 2020, the latest of several COVID-19 relief packages became law, as part of the Consolidated Appropriations Act, 2021 (the “New Law”). One of the most notable benefits-related provisions in the New Law...more
As part of the COVID-19 relief package passed by Congress earlier this week, the federal government expands on earlier relief issued by the Internal Revenue Service (IRS) for health and dependent care flexible spending...more
Summary - COVID-19 has dominated the agenda for health and welfare benefits in 2020. From suspended deadlines to mid-year election changes to enhanced cost-free coverage, the pandemic has resulted in significant changes to...more
On May 12, the IRS issued Notice 2020-29 “COVID-19 Guidance Under Section 125 Cafeteria Plans and Related to High Deductible Health Plans” and Notice 2020-33 “Section 125 Cafeteria Plans – Modification of Permissive Carryover...more
The IRS recently published two items of guidance to allow temporary changes to cafeteria plans. As a result of the guidance, employers may allow employees to make mid-year benefit election changes to respond to changed...more
On the latest episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses new opportunities that the IRS and COVID-19 legislative relief have created for health flexible spending and cafeteria plans....more
In response to the COVID-19 crisis, Congress and the IRS have provided more flexibility and expanded opportunities for employees to utilize health flexible spending arrangements and to adjust cafeteria plan elections. ...more
Many employers have sought to leverage or make changes to their employer-sponsored benefits to address economic and health-related burdens faced by their employees during the COVID-19 pandemic. Until now, however, employers...more