Today's Update

IRS Guidance

Guidance allowing extension of Governmental Plans to Charter School Employees

Notice 2015-7 provides guidance allowing governmental plans to cover charter school employees provided certain requirements are met. Document Excerpt The IRS and the Treasury Department anticipate issuing proposed regulations under § 414(d) of the Internal Revenue Code (Code) to define the term “governmental plan.” This document describes specific rules that the IRS and Treasury Department […]

Guidance for Certain Small Employers Unable to Access SHOP

Notice 2015-08 provides guidance on Section 45R for certain small employers unable to purchase health coverage through SHOP because the employer’s principal business address is in a county for which SHOP is currently not available. Document Excerpt  This notice provides guidance on section 45R of the Internal Revenue Code (Code) for certain small employers that […]

2015 Monthly National Average Bronze Level Premium

Revenue Procedure 2015-15 provides the average national monthly premium for bronze level plans under the Affordable Care Act to be used for purposes of the individual shared responsibility payment. Document Excerpt  This revenue procedure provides the 2015 monthly national average premium for qualified health plans that have a bronze level of coverage for taxpayers to […]

Guidance On Obtaining Determination Letters

As is customary, the IRS has released the -6 revenue procedure, i.e., Revenue Procedure 2015-6 which provides guidance on obtaining a determination letter from the IRS. Document Excerpt This revenue procedure sets forth the procedures of the Internal Revenue Service for issuing determination letters on the qualified status of pension, profit-sharing, stock bonus, annuity, and […]

Automatic Approval For Change in Funding Method

Announcement 2015-03 provides automatic approval for a change in funding method of a single employer defined benefit plan in the case of a takeover of the plan by a new service provider. Document Excerpt  This announcement provides automatic approval of a change in funding method with respect to a single-employer defined benefit plan under certain […]

Changes to Determination Letter Processing

Announcement 2015-01 announces changes to the processing of determination letter applications. Document Excerpt This announcement describes changes to the processing of employee plans determination letters that will take effect in 2015. These changes are being adopted as a result of a process improvement strategy designed to promote case processing efficiency. The changes to the determination […]

DOL Guidance

Guidance on Funding Notice post HATFA

Field Assistance Bulletin 2015-01 provides guidance on the funding notice requirement of ERISA Section 101(f) after the enactment of HATFA. Document Excerpt This memorandum provides guidance to the Employee Benefits Security Administration’s national and regional offices on compliance by plan administrators of single-employer defined benefit plans with the annual funding notice requirements of section 101(f) […]

Proposed SBC Fact Sheet

HHS releases an updated SBC Fact Sheet in conjunction with the release of the proposed changes to the rules governing the Summary of Benefits and Coverage. Document Excerpt  Proposed changes to the regulations regarding the summary of benefits and coverage (SBC) and uniform glossary for group health plans and health insurance coverage in the group […]

Updated SBC Template

In conjunction with the release of proposed changes to the rules governing the Summary of Benefits and Coverage, the Departments also release a revised Template. Document Excerpt Link http://www.dol.gov/ebsa/pdf/sbctemplateproposed.pdf

Proposed Summary Of Benefits and Coverage Regulations

The Departments release proposed regulations reflecting changes to the rules governing the Summary of Benefits and Coverage. Document Excerpt This document contains proposed regulations regarding the summary of benefits and coverage (SBC) and the uniform glossary for group health plans and health insurance coverage in the group and individual markets under the Patient Protection and […]

Proposed Changes to Excepted Benefit Rule

The agencies have proposed an amendment to the excepted benefit rules dealing with limited wraparound coverage. Document Excerpt This document contains proposed rules that would amend the regulations regarding excepted benefits under the Employee Retirement Income Security Act of 1974, the Internal Revenue Code (the Code), and the Public Health Service Act related to limited […]

Mental Health Parity Qs and As

The DOL has updated its Mental Health Parity Questions and Answers. Document Excerpt These FAQs provide basic information about the important protections MHPAEA provides with respect to parity in coverage of mental health and substance use disorder benefi ts and medical/surgical benefi ts provided by employment-based group health plans.   Link http://www.dol.gov/ebsa/pdf/cagmhpaea.pdf

PBGC Guidance

PBGC Website Updated To Reflect Increased Premiums

The increased premiums reflect changes made by the Multiemployer Pension Reform Act of 2014. Document Excerpt The per-participant flat premium rate for plan years beginning in 2015 is $57 for single-employer plans (up from a 2014 rate of $49) and $26 for multiemployer plans (up from a 2014 rate of $12). For information about future […]

Final Asset Allocation Rules

The PBGC releases its final asset allocation rules regarding the termination of a single employer plan. Document Excerpt This final rule amends the Pension Benefit Guaranty Corporation’s regulations on Benefits Payable in Terminated Single-Employer Plans and Allocation of Assets in Single-Employer Plans to prescribe interest assumptions under the benefit payments regulation for valuation dates in […]

PBGC Fall Regulatory Agenda

The PBGC releases is fall 2014 regulatory agenda. Document Excerpt Link http://www.reginfo.gov/public/do/eAgendaMain?operation=OPERATION_GET_AGENCY_RULE_LIST&currentPub=true&agencyCode=&showStage=active&agencyCd=1212

Amendments to Asset Allocation Regulations

The PBGC has issued amendments to its asset allocation regulations substituting a new table for determining expected retirement ages for participants in certain plans undergoing distress or involuntary terminations. Document Excerpt This rule amends the Pension Benefit Guaranty Corporation’s regulation on Allocation of Assets in Single-Employer Plans by substituting a new table for determining expected […]

Final Rule on 401(k) Rollovers to Defined Benefit Plans

The PBGC has issued its final rule on participant rollovers of 401(k) accounts to traditional defined benefit plans. Document Excerpt In April 2014, PBGC proposed to amend its regulations to clarify the treatment of benefits resulting from a rollover distribution from a defined contribution plan to a defined benefit plan, if the defined benefit plan […]

PBGC Lump Sum Rate

The PBGC announces the lump sum rate for December. Document Excerpt The immediate interest rate for valuing lump sum payments for the month of December 2014 is 1.00% and the deferred interest rate I1 is 4.00%, I2 is 4.00%, and I3 is 4.00%. Link http://www.pbgc.gov/prac/interest/monthly.html?cid=COLA01ABNOV15201417&source=govdelivery&utm_medium=email&utm_source=govdelivery

Articles, White Papers & Other Information

Proposed SBC Fact Sheet

HHS releases an updated SBC Fact Sheet in conjunction with the release of the proposed changes to the rules governing the Summary of Benefits and Coverage. Document Excerpt  Proposed changes to the regulations regarding the summary of benefits and coverage (SBC) and uniform glossary for group health plans and health insurance coverage in the group […]

Proposed Multiemployer Plan Legislation

The proposed legislation would, among other things, allow trustees of severely underfunded pension plans to adjust vested benefits. Document Excerpt Link http://amendments-rules.house.gov/amendments/KLINE129141934463446.pdf

Supreme Court to Hear Healthcare Subsidy Case

The U.S. Supreme Court has agreed to hear King v. Burwell, a case questioning the legitimacy of providing subsidies to individuals who purchase health coverage through the Federal, rather than through a State, Exchange. Document Excerpt QUESTION PRESENTED: Section 36B of the Internal Revenue Code, which was enacted as part of the Patient Protection and […]

Health Plan Identifier Delayed

The Office of e-Health Standards and Services announces a delay in enforcement of compliance with the Health Plan Identifier regulations. Document Excerpt The Health Plan Identifier (HPID) is a standard, unique health plan identifier required by the Health Insurance Portability & Accountability Act of 1996 (HIPAA).  On September 5, 2012 the Department of Health and […]

FAQs on HPID

CMS releases frequently asked questions on the Affordable Care Act’s health plan identifiers requirement. Document Excerpt Link https://questions.cms.gov/faq.php?isDept=0&search=HPID&searchType=keyword&submitSearch=1&id=5005

DC Circuit Holds that Subsidies May Not be Extended to Federal Exchanges

Issuing its ruling shortly before the Fourth Circuit upheld such subsidies, the DC Circuit holds that the Affordable Care Act’s subsidies may not be extended to those who purchase insurance through a Federal Exchange as the statute provides for such subsidies only when purchased under a state maintained exchange. Document Excerpt We conclude that appellants […]

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