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Telehealth Coverage Reinstated for HDHP/HSAs Effective April 1, 2022

The Consolidated Appropriations Act of 2022 (“2022 CAA”), which was recently signed into law, reinstates the exception that allows high deductible health plans (“HDHPs”) to waive all or a portion of participant cost-sharing...more

2022 Employee Benefit Plan Limits Announced by IRS

The IRS has released the 2022 cost-of-living adjustments for limits on employee benefits with some adjustments to the 2022 rates including minor increases to the maximum contributions allowed under Code Section 415 for...more

Reminder – Medicare Part D Notices due October 15, 2021

Group health plan sponsors must provide annual Medicare Part D Notices (the “Notice” or the “Notices”) by October 15, 2021. It’s your last chance to make sure your Notices will be timely delivered and comply with the legal...more

Utilizing Wellness Programs to Incentivize COVID-19 Vaccinations

Delta Airlines made headlines this month by announcing that it will charge employees on its group health plan a $200 surcharge for failure to receive the COVID-19 vaccination. Although there is potential for conflict with a...more

IRS Updates EPCRS Correction Program for Qualified Retirement Plans

The IRS released Revenue Procedure 2021-30, a new iteration of the Employee Plans Compliance Resolution System (“EPCRS”), on Friday, July 16. EPCRS permits sponsors of eligible tax-qualified retirement plans and 403(b) plans...more

COBRA Subsidies are Revived — Last-Minute Guidance May Have Expanded Your Duties

New guidance has been issued to clarify the Subsidized COBRA obligations imposed on employers and plan sponsors by the American Rescue Plan Act of 2021 (“ARPA”). This guidance comes at the last minute, as the deadline to send...more

COBRA Subsidies are Revived — Update

The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs or had a reduction in hours (and their family...more

Additional Employee Benefits Relief in the American Rescue Plan Act of 2021

President Biden signed The American Rescue Plan Act of 2021 (“ARPA”) into law on March 11, 2021, adding new employee benefits relief and providing extensions of prior COVID-19 relief. In our prior Alert[1] we discussed ARPA’s...more

COBRA Subsidies Are Revived

The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs (and their family members) the right to continue...more

Don’t Restart the Clock Just Yet – COBRA, HIPAA, Other Deadlines Might Be Further Extended!

At the last minute, certain suspended COBRA, HIPAA and claims procedure deadlines that were set to expire on February 28, 2021 have been further extended. As we discussed last year the Department of Labor (DOL) and Internal...more

New Year, New COVID-19 Relief for Employers and Plan Sponsors (Part 3)

The Consolidated Appropriations Act, 2021, H.R. 133 (the “CAA”) signed into law by the President on Dec. 27, 2020 and a variety of IRS guidance issued in the first week of 2021 mean that employers entering the new year have...more

New Year, New COVID-19 Relief for Employers and Plan Sponsors (Part 2)

The Consolidated Appropriations Act, 2021, H.R. 133 (the “CAA”) signed into law by the President on Dec. 27, 2020 and a variety of IRS guidance issued in the first week of 2021 mean that employers entering the new year have...more

New Year, New Covid-19 Relief for Employers and Plan Sponsors (Part 1)

The Consolidated Appropriations Act, 2021, H.R. 133 (the “CAA”) signed into law by the President on December 27, 2020 and a variety of IRS guidance issued in the first week of 2021 mean that employers entering the new year...more

Are You Counting LTPTEs for Your 401(k) Plan?

The Setting Every Community Up for Retirement Enhancement Act of 2019 (the Act) made changes in the qualified plan rules for eligibility and vesting with respect to so-called “long-term part-time” employees (LTPTE). The...more

2021 Employee Benefit Plan Limits Announced by IRS

The IRS has released the 2021 cost-of-living adjustments for limits on employee benefits with some adjustments to the 2021 rates including minor increases to the maximum contributions allowed under Code Section 415 for...more

IRS Updates Model Tax Notice

Section 402(f) of the Internal Revenue Code (“Code”) requires certain information to be provided to plan participants eligible to make rollover distributions. Periodically, the IRS has issued model 402(f) notices. ...more

New DOL E-Disclosure Rules Finally Bring Plan Administration Into the 21st Century

Late last week the U.S. Department of Labor (“DOL”) announced a final rule that brings retirement plan disclosures into the 21st Century by allowing widespread electronic delivery to workers (“Final E-Disclosure Rule”). ...more

IRS Notices Give Cafeteria Plan Flexibility for 2020

The IRS has issued Notices 2020-29 and 2020-33 (“Notices”) to give employers with Section 125 cafeteria plans, including health and dependent care spending accounts (FSAs), new flexibility to allow mid-year changes and...more

SECURE Act Highlights for Employers

At the end of December, 2019, the “Setting Every Community Up for Retirement Enhancement Act of 2019” or “SECURE Act” was enacted, making wide-sweeping changes to the employee benefits world. ...more

2020 Employee Benefit Plan Limits

The IRS has released the 2020 cost-of-living adjustments for limits on employee benefits with some adjustments to the 2020 rates including minor increases to the maximum elective deferrals, the maximum benefits allowed under...more

Class Action Exposure – Rates and Mortality Tables in Your Pension Plan

The phrase “actuarial equivalence” does not roll off anyone’s lips.  But, it may be the key phrase in the next wave of class action potential liability for defined benefit plans.  ...more

IRS Opens Determination Letter Program to Cash Balance Plans and Merged Plans

In an expansion of the IRS’ qualified retirement plan determination letter program, employers will now be able to seek an IRS favorable determination letter for individually-designed merged plans and, for a limited time,...more

Year-End Preparation and Hardship Withdrawals

With Thanksgiving on the horizon, now is the time to check on end of year changes for compliance for your 401(k), 403(b) and other defined contribution pension plans. ...more

2019 Employee Benefit Plan Limits Announced by IRS

The IRS has released the following 2019 adjustments for limits on employee benefits. For the first time since 2015, the highly compensated employee (HCE) limit has increased to $125,000. ...more

Matching Student Loan Repayments in a 401(k) Plan – A New Possibility

In a recent Private Letter Ruling (PLR 201833012), the IRS confirmed that an employer could make nonelective contributions to a 401(k) plan intended to “match” the participant’s student loan repayments....more

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