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 ...
As discussed in our previous posts, earlier this summer the PBGC issued FAQs that gave plan sponsors until October 15, 2020, to make their 2019 contributions and have that contribution reflected in the calculation of the variable rate premium due on that date. Under the FAQs, any contributions made for 2019 after the October 15, 2020 deadline could ...
This continues our series of posts regarding the IRS guidance on the SECURE Act. As discussed in our article earlier this year, the SECURE Act changed the eligibility and vesting requirements an employer can use with regards to part-time workers in its 401(k) plan. Earlier this month, the IRS issued Notice 2020-68, which has provided further ...
The IRS has again directed our attention back to the SECURE Act by issuing guidance related to qualified birth or adoption distributions. Withdrawals from a qualified retirement plan before age 59 ½ are generally subject to a 10% tax for early distribution, but as discussed in our blog post earlier this year, the SECURE Act created a new ...
As discussed in a prior blog post, the CARES Act allows defined benefit plan sponsors to delay any minimum required contribution for 2020 until January 1, 2021. However, the CARES Act did not delay the filing deadline for a plan’s Form 5500. This means that if a plan sponsor delays the contribution, as allowed by the CARES Act, to a date that falls ...