Earlier this week the IRS issued proposed regulations regarding an extension of the rollover period for certain plan loan offset amounts. The proposed rules implement portions of the Tax Cuts and Jobs Act (“TCJA”), which provides for an extended rollover period for a Qualified Plan Loan Offset (“QPLO”), which is a type of plan loan ...
Way back in December of 2019, the SECURE Act was passed into law and made significant changes to retirement benefit plans. It is easy to forget about the SECURE Act after the CARES Act and seemingly endless flow of administrative guidance that has come out since the national emergency caused by the coronavirus pandemic. But the Department of Labor ...
As discussed in a prior blog post, the Department of Health and Human Services’ Office for Civil Rights’ (“OCR’s”) issued its revised interpretation of Section 1557 of the Affordable Care Act (“ACA”). OCR’s revised interpretation eliminated “gender identity” from the list of protected classes. As At almost the same time ...
Plan administrators of qualified plans must provide participants that receive eligible rollover distributions with a written notice under Internal Revenue Code Section 402(f). In prior guidance issued in 2018, the IRS provided two safe harbor 402(f) notices that plans could use to meet the requirements of Section 402(f); one safe harbor ...
The Coronavirus Aid, Relief and Economic Security (“CARES”) Act extended the deadline for making 2019 defined benefit plan contributions to January 1, 2021. At the end of last month, the Pension Benefit Guaranty Corporation (“PBGC”) issued new FAQs to clarify when the 2019 contribution must be made in order for it to be reflected in ...
If you are a large employer required to provide health plan coverage to avoid the shared responsibility penalties, it is prudent to reevaluate your contribution structure each year before open enrollment to ensure that your plan is still “affordable.” Most employers were diligent about calculating affordability in the first few years ...
Earlier this week, members of health plans for two different employers filed a potential class action lawsuit against United Healthcare regarding cross-plan offsetting. This case comes nearly 18 months after United lost a similar case before the 8th Circuit Court of Appeals brought by care providers. This new case, Scott et al. v ...
Earlier this month, the Department of Labor (“DOL”) and Health and Human Services (“HHS”) released a proposed rule which provides more flexibility for grandfathered health plans to change cost-sharing requirements. A grandfathered health plan is generally a group health plan that has continuously provided coverage since March 23 ...
In our March blog post, we discussed the relief provisions for participants in defined contribution plans granted by Congress through the CARES Act, including coronavirus-related distributions (CRDs). The IRS has recently issued Notice 2020-50, which amended the definition of qualified individual (as discussed in our prior blog post) and ...
Last month, the U.S. Department of Health and Human Services (“HHS”) issued its final rule under Section 1557 of the Affordable Care Act that rescinded certain protections afforded to LGBTQ individuals and persons with limited English proficiency. In the same rule, HHS also removed burdensome disclosure requirements for health plans. Only ...