Several of our retirement plan clients lately have been the lucky winners of the “audit lottery” – seemingly standard requests by the Department of Labor for additional information and documents in preparation for an on-site audit. It now appears routine for the DOL to request a copy of the fee disclosure documents provided ...
Prior to February, I never really understood the phrase “it takes a village to raise a child.” Then I gave birth to my first child and now that phrase hits home. While I never expected to compare raising a child to complying with a massive piece of legislation, in the case of the Affordable Care Act, I think it is comparable.
Over the ...
In December, we discussed why it is so important after the ACA for health FSA plans to be “excepted benefits.” In that blog post, we talked about the trap of employer credits and issues those can cause health FSAs. In this post, I want to explain several other practices which used to be common that cause a health FSA to not ...
…if not, you are in the minority. High-deductible health plans coupled with health savings accounts (HSAs) have gained increasing popularity over recent years. I read an interesting article that predicts that HSAs could quadruple their growth over the next six years. The article predicts that 50 million Americans will be ...
I asked myself this question many times and it took me quite some time to find the answer. The regulations on the new 6055 and 6056 rules make it very clear that even non-calendar year plans must begin reporting for the period beginning on January 1, 2015. The 6056 report requires a large employer to report each of its full-time ...
Where is one place you should never find private medical records? Dylan was right - the answer is blowing in the wind. But that is exactly what a man found while driving down a Kansas City street. When the man traced the flying records back to their source, he found a crew dumping the records into an open dumpster at Research Hospital ...
The general rule is that safe harbor 401(k) plans may not be amended mid-year with very limited exceptions. This rule is one that often frustrates plan sponsors and is one that the IRS has recently said it is taking under consideration. While the general rule still holds true, the IRS recently published guidance stating that plans ...
Lyndsey Barnett
The ACA has several new reporting requirements for insurers, self-funded plans and large employers. These new reports, referred to as the Section 6055 and 6056 reports, are intended to help the IRS determine who is subject to the individual mandate penalty and the employer pay or play penalties. Due to the complexity of the ...
The Urban Institute is generally viewed as a center-left policy research institute that has been supportive of the Affordable Care Act. That is why it is so surprising that it just published a brief suggesting the elimination of the employer mandate, along with its substantial penalties for failing to offer employees affordable ...
New York and Presbyterian Hospital (“Presbyterian”) and Columbia University (“Columbia”) are affiliated as the New York Presbyterian Hospital/Columbia University Medical Center. According to a recent report published by the HHS Office of Civil Rights (“OCR”), Presbyterian and Columbia are separate covered ...