Last month, the IRS issued a proposed rule that would expand the ability of health reimbursement accounts (“HRAs”) to reimburse employees tax-free for care or expenses from direct primary care arrangements (“DPCA”) and health care sharing ministries (“HCSM”). The proposed rule would allow payments for DPCA and for membership in ...
In our March Blog post, we discussed the relief provisions for participants in defined contribution plans granted by the Congress through the (at the time) newly enacted CARES Act. As you are by now more than likely aware, the CARES Act permitted plan sponsors to make several discretionary amendments, giving participants greater access to ...
In IRS Notice 2020-51, the IRS provides much anticipated guidance on the CARES Act provision waiving 2020 required minimum distributions (RMDs). Much of the guidance in the IRS Notice deals with the beyond the scenes nuts and bolts of how the RMD waiver and any repayments of RMDs taken earlier this year would work. But there are a number of items that ...
In what seems like ages ago, back in the summer of 2019, the United States Preventive Services Task Force (“USPSTF”) recommended that health plans cover pre-exposure prophylaxis (“PrEP”) for persons who are at high risk of HIV acquisition. Under the Affordable Care Act (“ACA”), USPSTF recommendations must be covered by ...
In a prior blog post, we discussed how COVID-19 presented a potential opportunity for employers to set up a leave-sharing program for those affected by COVID-19. At that time, we discussed IRS guidance related to major disaster leave-sharing programs. Those programs, if a very specific set of circumstances are met, permit employees to make a ...
Last week, Graydon’s Lyndsey Barnett, Employee Benefits and Executive Compensation attorney partnered with VonLehman CPA & Advisory Firm and Joanna Berding, ERISA Attorney at Pension Corporation of America (PCA), as they discussed the numerous legal changes that have occurred as a result of the COVID-19 pandemic and the changes ...
As discussed in our prior blog posts, the PCORI fee, thought dead in 2019, was reinstated and the amount updated. Knowing the new fee amount of $2.54 was step one. However, plan sponsors who wanted to move beyond step one could not because the IRS had not revised the Form 720.
Fortunately, late last week, the IRS did update the Form 720. You can find the ...
Many employers have been forced to make the difficult decision to reduce their workforces due to the economic impact of the coronavirus pandemic. A significant reduction of employees can have a widespread impact on many aspects of a business, and can even impact an employer’s retirement plan if the reduction has led to a “partial termination.”
As mentioned in our blog post last week, while the PCORI fee has been resurrected by the IRS, the amount of the fee for plan years ending after October, 2019 had not been updated. Today, the IRS released Notice 2020-44 which updates the fee amount and provides some limited transition relief.
The new amount used to calculate the PCORI fee for policy ...
If you are feeling a sense that the rules around benefits haven’t changed enough in the last three months, this is a reminder of a change made during the long ago time of December 2019. In those ancient times, the PCORI fee rose from the dead. We all thought the annual PCORI (Patient-Centered Outcomes Research Institute) was set to expire back in 2019 ...