COBRA Without the Bite
On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”). The ARPA mandated several important changes for both employers and…
Nonprofit Organizations and Benefit Plans
Retirement Plan Deadlines Extended Due to COVID-19
In response to the COVID-19 pandemic, the Internal Revenue Service and the Pension Benefit Guaranty Corporation extended many deadlines for retirement plans, discussed below. Remedial…
If Your Retirement Plan Holds Employer Securities, Keep an Eye on the Jander Case
“Employer securities” in retirement plans have been the source of a significant amount of litigation under the Employee Retirement Income Security Act of 1974, as…
The Brave New World of Fiduciary Responsibility for Benefit Plans
Most blog entries focus on new developments or recent legislation. This one’s a bit different. Its subject matter, fiduciary responsibility, is as old as ERISA…
SECURE Act Expands Eligibility for 401(k) Deferrals
A December 27, 2019 post to this blog by Jon Nason provided an overview of the many changes affecting retirement plans made by the SECURE…
PCORI Fee Resurrected
In the summer of 2019, I wrote a short blog on the death of the PCORI fee -- Ding, Dong, the PCORI Fee is Dead!. …
2020 Appropriations Act Contains Significant Retirement Provisions (Secure Act)
On December 20, 2019, President Trump signed the Further Consolidated Appropriations Act, 2020 (the “Appropriations Act”) that includes the “Setting Every Community Up for Retirement…
Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row
Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is…
Finally, Hardship Distribution Regulations are Final
The Treasury Department and the Internal Revenue Service (collectively referred to hereafter as “IRS”) on September 23, 2019 published the final regulations on hardship distributions,…
IRS Expands Preventive Care Benefits Under High Deductible Health Plans
On July 17, 2019, the Internal Revenue Service (the “IRS”) released Notice 2019-45 which expands the list of permissible preventive care benefits for high deductible…