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Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.Blog Contributors
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Final Touches: IRS Clarifies Impact of COVID-19 Disaster Relief on COBRA Payment Deadlines
The Internal Revenue Service recently issued guidance to clarify the interaction between COVID-19 disaster relief and premiums due for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”). As summarized here, the Joint Notice and the EBSA … Continue reading
Posted in Employee Benefits
| Tagged ARPA, COBRA, covid, deadlines, examples, Notice 2021-58, premiums
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In Case You Missed It – Summer 2021
Summer has come and gone, but there was no summer vacation for employee benefits legislation and guidance. In case you have been too busy to check out our blogs lately, here are some key items to help you stay organized … Continue reading
Posted in Employee Benefits
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New Ways to Self-Correct Overpayments Under EPCRS
On July 16, 2021, IRS issued Revenue Procedure 2021-30 to update the Employee Plans Compliance Resolutions System (the “EPCRS”). The update in part expands the opportunities for plan sponsors to self-correct failures under the EPCRS by: (1) extending the self-correction … Continue reading
Posted in Employee Benefits, Qualified Retirement Plans
| Tagged EPCRS, IRS, qualified retirement plans
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SEC Approves Nasdaq’s Board Diversity Rules
On August 6, 2021, the Securities and Exchange Commission (“SEC”) adopted the Nasdaq Stock Market LLC’s (“Nasdaq”) proposed board diversity rule. The rule is intended to encourage greater board diversity by requiring board diversity disclosures for Nasdaq-listed companies. As explained … Continue reading
Posted in Employee Benefits
| Tagged Corporate Communicator, diversity, equity, inclusion, Nasdaq, SEC
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Departments Provide Some Relief to Health Plan Sponsors Facing Looming Year-End Deadlines
Year-end is always a scramble for health plan sponsors as they go through renewal and open enrollment. This year was looking to be worse than normal given the impending deadlines for complying with the transparency in coverage regulations (“TiC”) and … Continue reading
Posted in Employee Benefits, Health Care Reform
| Tagged ACA, CAA, deadlines, health and welfare, transparency in coverage
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Better Late Than Never: IRS Issues Guidance Clarifying COBRA Premium Subsidy Rules
S&W Insight: The IRS clarified several trailing issues with respect to COBRA premium subsidies under the American Rescue Plan Act, including extended election periods, eligibility for other coverage, and rules about allocating premium credits among employers. In addition, a notice … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged american rescue plan, ARPA, COBRA, cobra premium, IRS, notice requirement, subsidy
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Not All Surprises Are Good – Phase I of the Surprise Billing Rules
On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services, and Department of Labor issued the interim final rule “Requirements Related to Surprise Billing; Part I” (the “IFR”), which is the … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Department of Labor, ifr, no surprises act, surprise billing
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Updated Nonqualified Deferred Compensation Plan Audit Guide
In June the Internal Revenue Service released an updated Nonqualified Deferred Compensation Audit Technique Guide. This updated Guide replaces the initial Guide published in 2015. While it is too early to say whether the release of the updated guidance signals … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, nonqualified deferred compensation, Section 409A
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For the Long Haul: SCOTUS Ruling Means ACA Coverage and Reporting Rules Here to Stay
Despite myriad legal challenges, the Affordable Care Act (“ACA”) remains the law of the land. We previously reported on the Supreme Court’s latest validation of the law in our SW Benefits Update, “Three Strikes You’re Out – The Affordable Care … Continue reading
Posted in Employee Benefits
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CalCurrent Podcast and Equity Compensation for Startups
On May 13, 2021, Phoenix executive compensation and employee benefits partner, Greg Gautam, joined Snell & Wilmer’s “CalCurrent” podcast. On his episode, Greg covered five common pitfalls private companies and startup companies should watch out for when structuring their equity … Continue reading
Posted in Employee Benefits, Executive Compensation, Qualified Retirement Plans
| Tagged calcurrent, equity compensation, incentive programs, podcast, private company, startup
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