News & Analysis as of

Consolidated Appropriations Act (CAA) Flexible Spending Accounts

Schwabe, Williamson & Wyatt PC

Year-End Compliance Checklist for Employee Benefit Plans

As we come to the end of the year, it is a good time for employers with January 1st health plan renewals to review their plan documents and get ready for open enrollment. The following is a checklist that lists some of the...more

Pullman & Comley - Labor, Employment and...

December 31, 2022, is 125 Plan Amendment Deadline for COVID-19 Special Rules

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

Husch Blackwell LLP

Planning for 2022: Year-End Deadlines and Considerations for Employee Retirement, Health and Welfare Plans

Husch Blackwell LLP on

With the end of the year fast approaching, employers should be aware of several important deadlines and considerations related to retirement and health and welfare plans. With the onslaught of recent COVID-19-related...more

Ballard Spahr LLP

Upcoming Compliance Deadlines for Health and Welfare Plans

Ballard Spahr LLP on

Summary - Throughout 2020 and 2021, employers sponsoring health and welfare plans have needed to respond to a myriad of legislative and regulatory changes arising from the COVID-19 pandemic and new health legislation. To...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Are Your Employee Benefits Plans Ready for the New Year or Is It the Same Auld Lang Syne?

Holiday season and the end of the year are both quickly approaching, and with the turning of the calendar from 2021 to 2022 come several employee benefit plan amendment deadlines and implementation requirements. Some of these...more

Ballard Spahr LLP

IRS Issues Additional Dependent Care FSA Guidance

Ballard Spahr LLP on

Following up on guidance issued in February the IRS has issued a new notice on the temporary carryover rules for dependent care flexible spending accounts. The 2021 Consolidated Appropriations Act (CAA) provides that, for...more

Bradley Arant Boult Cummings LLP

IRS Answers Questions on Taxation of DCAPs and COVID-19 Relief

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

Holland & Hart - The Benefits Dial

Nobody Puts Baby In the Corner . . . And the IRS Agrees, Providing Guidance on the Taxability of Dependent Care Assistance...

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

Sullivan & Worcester

Keeping Up With All The Changes

Sullivan & Worcester on

The Coronavirus Aid, Relief, and Economic Security Act of 2020 (CARES Act), the Consolidated Appropriations Act, 2021 (CAA) and now the American Rescue Plan Act of 2021 (ARPA) each include many provisions that affect...more

BCLP

BCLP Benefits Newsletter: Q1 2021

BCLP on

ARPA provides that, for the period from April 1, 2021 until September 30, 2021, if an individual’s Consolidated Omnibus Budget Reconciliation Act (“COBRA”) qualifying event is an involuntary termination of employment or a...more

Robinson & Cole LLP

New Opportunities and Issues for Dependent Care Flexible Spending Accounts in 2020 and 2021

Robinson & Cole LLP on

The COVID-19 pandemic and large-scale “stay at home” orders left many employers facing questions relating to the elections employees made with respect to their dependent care benefit accounts. Since then, a number of major...more

Dickinson Wright

IRS Issues Guidance on the CAA Changes for Flexible Spending Accounts: Good News for Participants but Additional Administrative...

Dickinson Wright on

The IRS recently issued Notice 2021-15 to provide guidance on certain provisions of the Consolidated Appropriations Act of 2020 (the "CAA") affecting the administration of flexible spending accounts ("FSAs"). The CAA changes...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

COVID-19 Cafeteria Plan Relief: IRS Clears the Mud

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

Holland & Hart - The Benefits Dial

Whoomp There It Is…The IRS Issues Further Flexible Spending Account Relief under Notice 2021-15

Earlier this year, Bret Busacker explained the FSA relief enacted as part of the Consolidated Appropriations Act, 2021 (CAA) in a blog post titled “Bridge Over Troubled Water: 2021 Flexible Spending Account Relief in the...more

McDermott Will & Emery

Weekly IRS Roundup March 1 – March 5, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 1, 2021 – March 5, 2021... March 1, 2021: The IRS issued Notice 21-20 providing guidance...more

Robinson & Cole LLP

IRS Issues More COVID-Related Guidance on Flexible Spending Accounts

Robinson & Cole LLP on

On February 18, 2021, the IRS released Notice 2021-15 (the Notice), which provides additional guidance clarifying many open issues following implementation of Section 214 of the Consolidated Appropriations Act (CAA). Section...more

Fisher Phillips

Overview Of Employee Benefit Provisions In The Consolidated Appropriations Act

Fisher Phillips on

The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more

Patterson Belknap Webb & Tyler LLP

IRS Guidance on Additional Flexible Spending Account and Mid-Year Election Relief Under Cafeteria Plans in 2021 and 2020

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

Perkins Coie

IRS Clarifies Extended Cafeteria Plan Relief

Perkins Coie on

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

Foley & Lardner LLP

IRS Provides Further Flexibility for Flexible Spending Accounts

Foley & Lardner LLP on

Following up on changes to flexible spending accounts (FSAs) implemented by the December 2020 budget bill (the Consolidated Appropriations Act, 2021), the IRS provided interpretative guidance of its own in Notice 2021-15. ...more

Bradley Arant Boult Cummings LLP

Top 20 Takeaways from Notice 2021-15 for Employers with Cafeteria Plans

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

Stinson LLP

IRS Guidance on CAA Coronavirus Relief for FSAs, DCAPs and Cafeteria Plans

Stinson LLP on

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

Morgan Lewis

IRS Gymnastics With Code Section 125 for FSAs: Notice 2021-15

Morgan Lewis on

As discussed in our earlier LawFlash, the Consolidated Appropriations Act, 2021 (Act) contains certain permissible provisions plan sponsors may adopt to offer employees greater flexibility under a healthcare flexible spending...more

Stinson - Benefits Notes Blog

IRS Guidance on Coronavirus Relief for FSAs, DCAPs, and Cafeteria Plans: Almost Anything Goes

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

McAfee & Taft

New IRS guidance provides even more flexibility for cafeteria plans, FSAs, and DCAPs

McAfee & Taft on

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

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