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
We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more
Final Regulations under Section 36B of the Internal Revenue Code - On October 11, 2022, the Internal Revenue Service (IRS) issued Final Regulations under Code Section 36B relating to eligibility for the Affordable Care...more
Just prior to the start of 2023 open enrollment season, the IRS finalized new rules that will now make it easier for some families to access premium tax credits (PTC) for health insurance purchased through an exchange...more
On October 11, 2022, the IRS and the Treasury Department released final regulations relating to premium tax credit eligibility for families, along with companion cafeteria plan guidance in Notice 2022-41. The final...more
Employers who are interested in designing different benefits packages for different categories of employees must comply with both the Internal Revenue Code and the Affordable Care Act. ...more
On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....more
As background, before 2014, an employee’s election to enroll in his or her employer’s health plan pursuant to a cafeteria plan was irrevocable for the entire plan year, unless the employee incurred an event that affected his...more
In 2014, the Internal Revenue Service (IRS) expanded the events that would allow employees to drop their health plan coverage under their employer’s cafeteria plan. As a reminder, the general rule is that once an employee...more
This is a re-issued advisory reminding health plan sponsors that if you have administered your cafeteria plan in accordance with this guidance, make sure to execute a formal plan amendment by the end of the 2015 plan year...more
As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more
New IRS guidance adds two more events that allow participants to change their cafeteria plan elections outside of the annual open enrollment period. These events are designed to coordinate with the employer coverage rules and...more
Many employers permit employees to pay for employer-sponsored health coverage, on a pre-tax basis, under Internal Revenue Code section 125 (“cafeteria”) plans. These plans generally require employees to make an irrevocable...more
Employers and other health plan sponsors may be focused on preparing for the commencement of the employer mandate under the Affordable Care Act on January 1, 2015, but a number of other deadlines and developments are emerging...more
As the federal government agencies continue to push forward with implementation and administration of health care reform (i.e., the Patient Protection and Affordable Care Act), there are two recent developments that we want...more
Under Notice 2014-55, the Internal Revenue Service (IRS) will now permit a cafeteria plan to allow an employee to revoke his election for coverage under the employer's group health plan in order to purchase a qualified health...more
The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more
The Treasury Department and the IRS had a busy week issuing no less than five Affordable Care Act guidance items, consisting of...more
On Thursday, September 18, 2014, the Internal Revenue Service (“IRS”) released Notice 2014-55, which expands the cafeteria plan “change in status” rules to allow plans to offer employees an option to revoke their elections...more
Following Hawaii’s enactment of legislation recognizing same-sex marriage as of and after December 2, 2013 a number of additional pieces of guidance were also issued. Internal Revenue Service’s Frequently Asked Questions...more
As we approach the end of the year, employers and plan sponsors of qualified retirement plans and health and welfare plans should take time to meet various upcoming deadlines. Failure to comply with the deadlines may result...more
Under new IRS guidance, an employer may amend its cafeteria plan to allow for up to $500 of unused amounts remaining in a health flexible spending account (FSA) at the end of a plan year to be carried forward to reimburse...more
On October 31, 2013, the Internal Revenue Service (IRS) released Notice 2013-71 (Notice), which modifies the "use or lose" rule for health flexible spending accounts (health FSAs) to allow a $500 annual carryover of unused...more
Last week, there were two important developments relating to Section 125 cafeteria plans. First, Massachusetts announced that employers will no longer be required to maintain a Section 125 plan. Second, the IRS has modified...more
In Notice 2013-71 (the “Notice”), the Internal Revenue Service (the “IRS”) has modified the so-called “use-it-or-lose-it” rule for health flexible spending accounts (“FSAs”) under cafeteria plans to allow participants to...more
On October 29, 2013, the Massachusetts Connector released Bulletin 03-13, which sets forth a significant course change in the Commonwealth’s cafeteria plan, HIRD, and free rider surcharge rules....more