Today's Update

IRS Guidance

Guidance on the Corporate Bond Rate

Notice 2014-73 provides guidance on the corporate bond monthly yield curve. Document Excerpt This notice provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the Internal Revenue Code. In addition, this notice provides guidance as to […]

Additional Guidance on the One-Rollover-Per Year Rule

Announcement 2014-32 provides additional guidance on the IRS’ revised interpretation of the one-rollover-per year rule. Document Excerpt This announcement is a follow-up to Announcement 2014-15, 2014-16 I.R.B. 973, addressing the application to Individual Retirement Accounts and Individual Retirement Annuities (collectively, “IRAs”) of the one-rollover-per-year limitation of § 408(d)(3)(B) of the Internal Revenue Code.   Link […]

Health Plans failing to Provide In-Patient Hospitalization Do Not Provide Minimum Value

The IRS has released Notice 2014-69 clarifying that a plan that fails to provide in-patient hospitalization services does not provide minimum value without regard to the outcome of the use of the calculator. Document Excerpt  The Department of Health and Human Services (HHS) and the Department of the Treasury (including the Internal Revenue Service) (collectively, […]

2015 Inflation Adjusted Limits Including Section 125

Revenue Procedure 2014-61 contains non-retirement plan 2015 inflation adjusted limits. Document Excerpt This revenue procedure sets forth inflation-adjusted items for 2015.   Link http://www.irs.gov/pub/irs-drop/rp-14-61.pdf

Lifetime Income through Target Date Investments

Notice 2014-66 provides guidance on the provision of lifetime income in a defined contribution plan through investment in a series of target date investment options. Document Excerpt This notice provides a special rule that enables qualified defined contribution plans to provide lifetime income by offering, as investment options, a series of target date funds (TDFs) […]

2015 Benefits Limitations

The IRS has released updated benefit limits for 2015 taking into consideration cost of living increases. Document Excerpt The Internal Revenue Service today announced cost-of-living adjustments affecting dollar limitations for pension plans and other retirement-related items for tax year 2015. Many of the pension plan limitations will change for 2015 because the increase in the […]

DOL Guidance

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

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 […]

Guidance on State Regulation of Stop-Loss Insurance

The DOL has posted to its site Technical Release 2014-01 providing guidance on state regulation of stop-loss insurance. Document Excerpt The Department of Labor, which is the agency primarily tasked with administration of Title I of ERISA,(9) takes the view that States may regulate insurance policies issued to plans or plan sponsors, including stop-loss insurance […]

Implementation FAQs Part XXII

The DOL has released Frequently Asked Questions Implementation Part XXII regarding the implementation of the Affordable Care Act. Document Excerpt Set out below are additional Frequently Asked Questions (FAQs) regarding implementation of the Affordable Care Act. These FAQs have been prepared jointly by the Departments of Labor (DOL), Health and Human Services (HHS), and the […]

Information Letter on Use of Target Date Funds for Lifetime Income

In conjunction with the IRS’ release of Notice 2014-66, the Department of Labor has issued an Information Letter discussing the implications of using a series of target date funds to provide lifetime income from a defined contribution plan. Document Excerpt This responds to your request for the Department of Labor’s (the Department) views on whether […]

Affordable Care Act Implementation Part XXI

The DOL releases the Affordable Care Act Implementation Qs & As Part XXI. Document Excerpt Set out below is an additional Frequently Asked Question (FAQ) regarding implementation of the Affordable Care Act. This FAQ has been prepared jointly by the Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments). Like […]

PBGC Guidance

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

Disaster Relief For Parts of California

The PBGC has announced disaster relief for affected plans in California as a result of the earthquake. Document Excerpt Pension Benefit Guaranty Corporation (“PBGC”) is waiving certain penalties and extending certain deadlines in response to the Earthquake that began on August 24, 2014, in California. Link http://www.pbgc.gov/prac/other-guidance/dr/dr14-07.html

PBGC Announces Maximum Guaranteed Benefits for 2015

  The PBGC has announced the maximum benefit level to be guaranteed by the PBGC for 2015.   Document Excerpt Maximum Guarantee: On October 27th, 2014, PBGC announced that the annual maximum guaranteed benefit for a 65-year-old retiree in a single-employer plan increases to $60,136 for 2015, up from $59,318 for 2014.  A table showing […]

2015 Premium Rates

The PBGC has updated its website to reflect the 2015 PBGC premium rates. 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 $13 for multiemployer plans (up from a 2014 rate of $12). For information about future rates, […]

Guidance on HAFTA and 4010 Reporting

Technical Update 14-2 provides guidance on the effect of HAFTA on 4010 reporting. Document Excerpt This Technical Update 14-2 provides PBGC guidance on the effect of the Highway and Transportation Funding Act of 2014 (HATFA) on annual financial and actuarial information reporting under section 4010 of ERISA and part 4010 of PBGC’s regulations.1  This Technical […]

November Lump Sum Rate

The PBGC announces the November lump sum interest rate. Document Excerpt The immediate interest rate for valuing lump sum payments for the month of November 2014 is 1.25% and the deferred interest rate I1 is 4.00%, I2 is 4.00%, and I3 is 4.00%. Link http://pbgc.gov/prac/interest/monthly.html?cid=COLA01ABOCT1520141&source=govdelivery&utm_medium=email&utm_source=govdelivery

Articles, White Papers & Other Information

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 […]

Fourth Circuit Upholds Federal Exchange Subsidies

Concluding that the statute and the legislative history was not clear, the Fourth Circuit upheld the regulatory interpretation allowing subsidies to those who otherwise qualify but who purchase under Federally established exchanges. Document Excerpt It is thus entirely sensible that the IRS would enact the regulations it did, making Chevron deference appropriate. Confronted with the […]

Definition of “State” For purposes of ACA

The CMS releases a letter discussing the definition of “state” for purposes of the Affordable Care Act and the impact on Puerto Rico and other U.S. Territories. Document Excerpt After a careful review of this situation and the relevant statutory language, HHS has determined that the new provisions of the PHS Act enacted in title […]

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