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While it may be early to be thinking about next year for some, others are already knee deep in making health plan changes for 2020.  For those that like to get a jump on planning for next year, the IRS just announced the new 2020 contribution limits for a health savings account (“HSA”), as well as the 2020 minimum deductible and maximum ...

The following facts lead to a common situation experienced by many employers:

  • Employee participates in the employer’s medical plan;
  • Employee makes contributions to the plan for his share of the premium payment though payroll deductions;
  • Employee later goes on unpaid FMLA leave, and during Employee’s leave the premium payments are no ...

At a conference late last week, an IRS official announced that the IRS was working on guidance to answer the many questions that it has received after the issuance of the PLR  last August approving a unique student loan repayment arrangement inside of a retirement plan.   With student loan debt continuing to rise and be an issue for employees, more and ...

Many self-funded health plan sponsors are aware that their plans are subject to HIPAA and that they must maintain policies and procedures to comply with the law. But compliance with HIPAA does not stop in the planning phase. As the threat and occurrence of security incidents become more and more common, plan sponsors must be ready to take action when ...

No.  Your eyes are not playing tricks on you and there is not a typo in my title.  HHS just announced that it is decreasing the annual limit on HIPAA violations for three of the four tiers of violations.

In 2009, Congress greatly increased the amount of penalties that HHS could assess for HIPAA violations in the HITECH Act.  HITECH established four tiers ...

In the latest version of the IRS’s correction program for retirement plans (referred to as EPCRS), the IRS has provided guidance that will make it easier for plan sponsors to correct certain plan loan errors. Prior to this guidance, all plan loan errors had to be corrected through either the Voluntary Correction Program (VCP) or Audit CAP ...

We frequently receive inquiries from clients asking us our opinion on whether the ACA will be struck down. We received these questions a lot in the first few years after the law was enacted and they have picked up again in the past year or so.   I don’t have a crystal ball, so I am never inclined to give a very definitive answer (and sorry  but you won’t get ...

The IRS issued a Notice on March 6th that makes the treatment of retiree lump-sum windows clear as mud. Retiree lump-sum windows previously allowed defined benefit plans to establish a temporary window for participants already receiving an annuity to elect to receive a lump-sum distribution in lieu of future annuity payments. That is until the ...

Section 101(k) of ERISA requires a multiemployer plan, upon written request, to furnish copies of certain actuarial and financial documents to any plan participant, beneficiary, employee representative, or any employer that has an obligation to contribute to the plan. The documents are supposed to be provided within 30 days after receiving ...

The question raised by this blog post can be answered with one sentence:

The buyer in an asset sale will be obligated to make COBRA continuation coverage available to M&A qualified beneficiaries with respect to that asset sale if the buyer is a successor employer.

Although this is an accurate statement and succinct answer, for this sentence to have ...

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