HDHP Telehealth Relief Extended for Remainder of 2022, but Mind the 3-Month Gap in Relief

On March 15, 2022, the Consolidated Appropriations Act, 2022 (the “2022 CAA”) was signed into law.  Section 307 of the 2022 CAA extends the relief permitting high deductible health plans (“HDHPs”) to provide telehealth and other remote care services free … Continue reading

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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

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Subsidized COBRA Elections under ARPA Override COBRA Election Deadline Extensions

As detailed in our SW Benefits Update, “Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act,” the IRS recently released Notice 2021-31 (the “Notice”), providing welcome guidance on the COBRA election … Continue reading

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Get Ready, Get Set, to Cover COVID-19 Vaccines for Free

Last month, we reported that Moderna was seeking FDA authorization for its COVID-19 vaccine and reminded readers about the immunization coverage requirements in Section 3202 of the CARES Act in our SW Benefits Blog, “Free COVID-19 Vaccine and Testing Update.”  … Continue reading

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Is Your Safe Harbor Section 401(k) Plan Required to Provide an Annual Notice?

Sponsors of safe harbor Section 401(k) plans should consider whether they are required to provide their annual safe harbor notice in 2020 for the upcoming 2021 plan year.  The Setting Every Community Up for Retirement (“SECURE”) Act, which was enacted … Continue reading

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New Year, New Age: the SECURE Act Increases the Required Minimum Distribution Age to 72

On December 20, 2019, President Trump signed the Further Consolidated Appropriations Act, 2020, a spending bill that includes the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”).  The SECURE Act initially passed the House in … Continue reading

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