The Bottom Line ARPA’s COBRA subsidy presents a number of complicated administrative issues that employers, plan sponsors and administrators, and insurers alike should consider. In particular, there are a number of nuances to how the Notice may impact plan sponsors.Plan sponsors should consult with Continue Reading
Regulators Clarify COVID-19 Relief Deadline Extension
The Bottom Line The newly issued Notice could be quite difficult to apply in practice for plan sponsors and third party administrators, as it requires a plan sponsor and its third party administrators to track each participant’s or beneficiary’s tolling period from the date he/she became entitled Continue Reading
IRS Provides Cafeteria Plans with Flexibility Due To COVID-19
The Bottom Line The IRS is allowing employers to amend their cafeteria plans for the 2020 tax year to permit employees to make new employee benefit elections with respect to their healthcare coverage, health FSAs and dependent care FSAs. Employers should work closely with their ERISA counsel to Continue Reading
Retirement Plans: Regulators Provide Relief from Certain ERISA Requirements During the COVID-19 Crisis
The Bottom Line The Notice provides valuable relief from the DOL’s enforcement of certain requirements under Title I of ERISA. However, the Notice does not affect a participant or beneficiary’s enforcement rights under ERISA.Much of the relief provides that enforcement actions will generally not be Continue Reading
Group Health Plans: Regulators Extend Deadlines During the COVID-19 Crisis
The Bottom Line The Notice provides important guidance and relief for group health plan sponsors and plan participants in light of the COVID-19 pandemic.The regulators have hit the pause button on many of the employee benefit plan timeframes during the period of the COVID-crisis.Since the guidance Continue Reading
Health and Welfare Considerations for Plan Sponsors Amid the COVID-19 Pandemic
The Bottom Line Employers should work closely with their ERISA counsel to ensure that their obligations with respect to health and welfare plans continue to be fulfilled, and that they are taking the appropriate steps to protect their employees and plans. As employers make changes to their Continue Reading
IRS Defers Tax Payment and Filing Obligations Due to the Coronavirus Pandemic
The Bottom Line The IRS has deferred income tax payments and income tax filings from the original deadline of April 15, 2020 to July 15, 2020.The deferral applies to income tax payments for 2019 and the first quarter estimated income tax payment for 2020, which for individuals, includes taxes on Continue Reading
IRS Reopens Its Determination Letter Program to Cash Balance Plans and Merged Plans
The Bottom Line Under the IRS’ expanded determination letter program, plan sponsors of statutory hybrid plans (e.g., cash balance plans) may now submit an application for a favorable determination letter for a 12-month period beginning September 1, 2019. Additionally, all retirement plans that Continue Reading
Student Loan Repayment Benefit Under a 401(k) Plan: An Important New Benefit That Employers Can Offer Right Now
The Bottom Line Employers who wish to attract and retain a young and educated workforce should consider amending their 401(k) plans to provide this benefit. Employers interested in providing this student loan repayment benefit should consult with ERISA counsel prior to Continue Reading
Take Compliance Seriously When Hiring Domestic Employees in New York
The Bottom Line The potential penalties and damages for failing to comply with the many legal requirements for hiring domestic staff serve as a reminder that, while employers may develop a great relationship with a domestic employee, things can always go sour later. When they do, the downside can Continue Reading