As discussed in our prior blog posts, the PCORI Fee was resurrected by the IRS last year. This past week, the IRS updated the amount of the PCORI Fee for policy years and plan years that end on or after October 1, 2020, and before October 1, 2021. The new amount of the PCORI Fee is $2.66 per covered life. The fee for plan years ending prior to October 1, 2020 ...
Earlier this fall, the Departments of Health and Human Services, Treasury, and Labor (the “Departments”) issued the final rule for “transparency in coverage” requirements for health plans and insurers. The final rule applies to most non-grandfathered group health plans and health insurance issuers will be required to comply with ...
The CARES Act extended the due date for making 2020 contributions to a defined benefit plan to January 1, 2021. In IRS Notice 2020-82, the IRS has now clarified that the 2020 contributions will be treated as timely if made by January 4, 2021, the first business day after January 1, 2021.
In response, the PBGC immediately adjusted its prior guidance ...
Many times, when faced with a possible compliance issue, plan sponsors will debate whether they should call their benefits attorney or not. While attorneys wish this wasn’t the case, it is understood. Fixing compliance issues costs money. No one likes to spend money. An attorney will tell you the risk depends on the circumstances and ask your ...
It is again time for plan sponsors to finalize and issue their annual notices to participants. We have experienced many legislative and economic changes since this time last year, so plan sponsors might have more to consider and update in this year’s annual notice outside of the normal changes to plan COLAs and investment expense ratios. As a ...
Last week, in a 2-1 decision, the Sixth Circuit Court of Appeals allowed DaVita Inc’s lawsuit against a health plan and its administrator to continue. In its suit DaVita alleges the plan discriminates against patients with end-stage renal disease (“ESRD”). Under the terms of the self-insured health plan, all dialysis providers were ...
The IRS released its annual update for the cost-of-living adjustments for 2021. In contrast with the changes made last year, many of the limitations remained unchanged, including the elective deferral limits for 401(k), 403(b), and 457(b) plans, the defined benefit plan limit, the dollar limitation on catch-up contributions for individuals ...
This is the time of the year when open enrollment occurs for many health plans. This is also the time of year when you can meet many of your annual legal notice responsibilities. Open enrollment is a busy time of year so it is a good idea to get into the habit of giving out your annual notices at the same time. This means there is one less thing to forget later ...
Over the past 7 months, the various government agencies have provided numerous pieces of relief to both participants and plan sponsors by extending deadlines on various employee benefit plan obligations. However, one requirement where no relief has been granted is the requirement for employers to send Medicare Part D notices of creditable ...
On Friday, the IRS issued a Notice that extends the deadline for large employers (generally those with 50 or more full-time equivalent employees in the previous year) and self-insured group health plans to distribute Forms 1095-C to employees and plan participants. This guidance looks almost identical to the relief provided for the 2019 tax ...