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As you have likely seen by now, over the weekend President Trump signed the Setting Every Community Up for Retirement Security Act (the “SECURE Act”) into legislation.  This is the largest piece of legislation impacting retirement plans since the PPA was enacted in 2006.   We will be addressing the impact of this legislation on your plan over a ...

The IRS again announced that it is extending 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 their Forms 1095-C to employees and plan participants.  The normal deadline to distribute Forms 1095-C is January 31st.  This IRS ...

Now that the cost of living adjustments have been issued for 2020, it is time for plan sponsors to finalize and issue their annual notices to participants. The 401(k) safe harbor, qualified default investment alternative (“QDIA”), and automatic enrollment notices must all be sent to plan participants between 30-90 days before the beginning ...

The IRS released its annual update for the cost-of-living adjustments for 2020. Consistent with the changes made last year, elective deferral limits for 401(k), 403(b), and 457 plans increased $500 from $19,000 to $19,500, the annual compensation limit increased $5,000 from $280,000 to $285,000, the defined contribution plan limit ...

By Alex Mattingly and Kitso Malthape

In November of 2018, we wrote a blog post about the IRS’ proposed regulations regarding changes to the hardship distribution rules. On September 19, 2019, the IRS and Treasury Department issued the final regulations for hardship distributions rules. The final regulations are substantially similar to ...

October 14th is the last day employers who sponsor group health plans can timely provide the Medicare Part D Notice to plan participants. This Notice is provided to inform participants whether or not your plan’s prescription drug coverage is expected to cover, on average, as much as the standard Medicare Part D plan. The notice must be distributed ...

We wrote a blog post last year on the proposed FAQs addressing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), specifically as it applies to self-funded group health plans that excluded Applied Behavior Analysis (ABA) therapy from plan benefit coverage. Last week, the Department of Labor (DOL), Health and Human Services ...

In April 2019, the Department of Health and Human Services (HHS) issued final regulations that were set to become effective January 1, 2020. HHS had expressed concern that the availability of a coupon may cause physicians and patients to choose an expensive brand name drug when a less expensive and equally effective generic or other alternative ...

Beginning in 2017, the IRS began accepting determination letter applications from an individually designed plan only for initial plan qualification and for qualification upon plan termination. Prior to 2017, these plans could submit an application once every five years to request the IRS’ blessing that its provisions were satisfactory ...

In 2013, the IRS established a program for issuing opinion letters for 403(b) pre-approved plans and began accepting applications for opinion letters. This program allows eligible employers that amend or restate their plans to retroactively correct defects in form of written 403(b) plans going back to the first day of the remedial amendment ...

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