Understanding Employee Benefits

IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA

On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the American Rescue Plan Act of 2021 (ARPA).  For more information about the ARPA and COBRA subsidies, see Stinson’s previous blog:... Read More

Topics: Health Plan, Multi-employer Plans

DOL Issues First Ever Cybersecurity Guidance

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On April 14, 2021, the Department of Labor’s (DOL) Employee Benefits Security Administration issued guidance on cybersecurity for the first time to help plan sponsors, fiduciaries, service providers, and participants protect personal information and retirement assets. In the guidance, the DOL identifies evaluating cybersecurity practices as part of the plan... Read More

Topics: Fiduciary Guidance, Retirement Plans

DOL’s ARPA COBRA Subsidy Notices and FAQs: Stay Tuned for More

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On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law. Under ARPA, certain employees and their dependents who lost group health coverage during the COVID-19 pandemic due to the employee’s involuntary termination (other than for gross misconduct) or reduction of hours are allowed... Read More

Topics: Cafeteria Plans, Health Plan, Payroll, Welfare Plans

AMERICAN RESCUE PLAN ACT CONTAINS MANY EMPLOYEE BENEFITS RELATED PROVISIONS

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the “ARPA”) into law.  Many of the provisions in this sweeping legislation bring changes to the employee benefits world of which employers should take note and which are summarized below. Subsidized COBRA The ARPA contains several... Read More

Topics: Executive Compensation, Health Plan, Multi-employer Plans, Retirement Plans

IRS Guidance on Coronavirus Relief for FSAs, DCAPs, and Cafeteria Plans: Almost Anything Goes

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On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (“FSAs”), and dependent care assistance programs (“DCAPs”) that were included in the Consolidated Appropriations Act (“CAA”), enacted on December 27, 2020.  The Notice also adds temporary opportunities to make changes... Read More

Topics: Cafeteria Plans, Health Plan

Annual Limits on Qualified Plans for 2021

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On October 26, 2020, the Internal Revenue Service (IRS) released Notice 2020-79, which sets forth the 2021 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the dollar limitation for employee salary reductions for contributions to health flexible spending arrangements in Revenue... Read More

Topics: Cafeteria Plans, Health Plan, Retirement Plans

IRS Issues Additional Guidance on Coronavirus-Related Distributions and Plan Loans under CARES Act

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On Friday, June 19, 2020, the IRS released Notice 2020-50 which provides additional guidance regarding the coronavirus-related distributions (“CRDs”) and coronavirus-related loans and loan repayment delays (“CR Loan Relief”) made available to certain retirement plan participants affected by COVID-19 under the CARES Act. The notice expands, and in some cases... Read More

Topics: Retirement Plans

DOL Provides its view on Private Equity Investment Exposure in Defined Contribution Plans

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In a new information letter, the U.S. Department of Labor (DOL) concludes offering professionally managed asset allocation funds, which include a private equity component as an investment option in an individual account plan (e.g., a 401(k) plan), is not a per se violation of ERISA. Plan fiduciaries commonly invest defined... Read More

Topics: Fiduciary Guidance, Retirement Plans

New DOL Electronic Disclosure Safe Harbor Offers Relief for Retirement Plans

The Department of Labor has issued final regulations that will enable employers to electronically provide required information and documents to more plan participants.  Although employers have been able to electronically provide some documents and information to some participants under existing rules, use of electronic delivery was limited because of an... Read More

Topics: Retirement Plans

IRS Answers Some FAQs on Coronavirus-Related Distributions and Loans

On May 4, 2020, the IRS provided guidance on coronavirus-related distributions (“CRDs”) and coronavirus-related loans and loan payment delays (“CR Loan Provisions”) in the form of FAQs.  In those FAQs, the IRS answered a few of the questions that many practitioners, administrators, and employers have been asking: Does a spouse’s... Read More

Topics: Retirement Plans