Just moments after hanging up the phone with a client confirming for them that there has been no relief under Section 125 on mid-year changes that are not HIPAA special enrollment events , the IRS issues Notice 2020-29 and Notice 2020-33 providing guidance that makes the advice I gave 5 minutes before invalid. We are on the fastest freight train of ...
To echo my colleague in another post, in nearly 20 years of practice I have never seen so much benefits related guidance in such a short period of time. It seems like just yesterday the IRS and DOL issued a joint notice providing some deadline relief for COBRA and HIPAA related matters. Today, we receive more complex guidance when the IRS released Notices
As mentioned in our prior blog post, the DOL and IRS have recently issued coordinated guidance that provides relief for benefit plans by extending certain deadlines. This post examines the limited relief granted to retirement plans by extending the amount of time a plan has to distribute participant contributions and loan repayments into ...
Have you ever experienced an employee attempting to enroll their spouse a month and a half after getting married or an employee attempting to enroll a newborn child 40 days after the birth? Normally, these enrollments would not be permitted given that the employee notified you outside of the 30-day HIPAA special enrollment window. Well along ...
This week the DOL and IRS issued a joint rule which provides relief from certain deadlines for group health plans, other welfare benefit plans, and retirement plans. The guidance applies to all plans covered by ERISA or the Code, and HHS has announced it will extend similar relief to non-federal governmental health plans. This post examines the ...
Earlier this month, the IRS announced that it had extended deadlines for filing federal income tax returns and making tax payments due to the COVID-19 pandemic, which had a small effect on benefit plans. The IRS has since amplified this relief through Notice 2020-23 and provided additional relief that is more significant for benefit plans.
This past week, the Pension Benefit Guaranty Corporation (“PBGC”) announced it had extended deadlines for upcoming premium payments and other filings due to the COVID-19 pandemic. The PBGC’s announcement came after the IRS extended its deadlines to July 15, 2020. Under the PBGC’s disaster relief policy, when the IRS announces ...
Most small businesses are aware of the loans backed by the Small Business Administration (“SBA”) to help maintain cash flow and retain workers, specifically the Paycheck Protection Program (“PPP”). While most of the media, and our prior blog post, focused on how to apply for these loans and the fact the loan is forgivable if used for ...
Under the FMLA, an employer is required to continue an employee’s group health plan coverage at active employee rates during the length of the FMLA leave. Therefore, it came as no surprise that the DOL temporary regulations that were released yesterday on the Emergency Paid Sick Leave Act (“EPSLA”) and the Emergency Family Medical Leave ...
The IRS has extended the deadlines for plan sponsors to adopt certain retirement plans as a result of the Coronavirus emergency.
403(b) Plans
In 2013, The IRS initiated a 403(b) program that allows eligible employers to amend or restate their plans retroactively. Plan sponsors could correct defects in their written plan document going back as far ...