Last July, in Announcement 2015-19, the IRS announced that it was terminating its determination letter program for individually designed qualified retirement plans, other than for new or terminating plans. This week, in Notice 2016-03 the IRS provided us with specific transition guidance on the winding down of its program. Specifically, the IRS announced that: Controlled […]
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The Civil Rights Office of the Department of Health and Human Services announced a “Phase 2” audit program in the Fall of 2014. That audit program was delayed due to funding issues, but appears to be back on schedule for 2015. These Phase 2 audits are expected to be more in depth and focused on […]
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On October 31, 2014, HHS announced a delay, “until further notice,” in the enforcement of the regulations pertaining to Health Plan Identifiers (HPIDs) and their use in HIPAA standard electronic transactions. For more information on the HPID requirements, please see our October 1, 2014 SW Benefits Update, “HIPAA Requires Many Health Plans to Obtain a […]
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On January 17, 2013, the U.S. Department of Health and Human Services (HHS) issued a final rule under HIPAA making substantial changes to the rules for vendors that provide services to HIPAA-covered plans, such as third-party administrators, pharmacy benefit managers and certain brokers – known in the HIPAA world as “Business Associates.” Under this final […]
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The Supreme Court recently ruled in U.S. v. Quality Stores that severance paid to employees is considered wages for FICA purposes. Before the Court’s decision, there was little doubt that employer-provided severance was wages for income tax purposes, but lower court cases were a mixed bag about whether severance was wages for FICA tax purposes. […]
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