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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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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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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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Credit Where Credit Is Due: IRS Offers Long-Sought Guidance on Employer Retention Credit Program
As we previously reported, the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”) provided for an employee retention credit (“ERC”) designed to encourage employers to retain workers during the COVID-19 crisis. In general, the ERC permits eligible employers … Continue reading
Posted in Employee Benefits, Executive Compensation, Health & Welfare Plans, Health Care Reform, Qualified Retirement Plans
| Tagged CAA, CARES Act, eligible employer, employee retention credit, ERC, paycheck protection program, PPP, Qualified wages
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IRS Clarifies SECURE Act Changes to Qualified Automatic Contribution Arrangements
The IRS recently published Notice 2020-86 (the “Notice”), which provides clarification with respect to certain changes made by the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). In particular, the Notice answers several outstanding questions … Continue reading
Posted in Employee Benefits, Qualified Retirement Plans
| Tagged automatic contribution, IRS, Notice 2020-86, qaca, qualified automatic contribution arrangement, SECURE, treasury
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Finally, Some Good News: IRS Extends Certain ACA Reporting Deadlines and Transition Relief
As in prior years, the IRS has provided relief for employers preparing to comply with the Affordable Care Act’s (“ACA”) information reporting requirements in early 2021 for the 2020 calendar year. In particular, Notice 2020-76 (the “Notice”) extends the deadline … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, deadlines, extension, notice 2020-76, reporting
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Enjoy the End of the Decade with Some Employee Benefit Plan Checklists
Each year, we publish health and welfare, cost-of-living, qualified retirement plan, and executive compensation plan checklists to help individuals and employers stay apprised of updates to the law of employee benefits. We just published the last of these annual checklists. … Continue reading
Posted in Employee Benefits, Executive Compensation, Health & Welfare Plans, Health Care Reform, Qualified Retirement Plans
| Tagged checklists, COLA, cost-of-living, ERISA, Executive Compensation, Internal Revenue Code, qualified retirement plan, to do list
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A Post-Thanksgiving Treat: IRS Extends Certain ACA Reporting Deadlines and Transition Relief
The IRS provided welcome news to employers preparing to comply with the Affordable Care Act’s (“ACA”) information reporting requirements in early 2020 for the 2019 calendar year. In particular, Notice 2019-63 (the “Notice”) extends the deadline to furnish Forms 1095-B … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged ACA, deadlines, extension, Form 1095-B, Form 1095-c, good faith, notice 2019-63, reporting
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Form 5500 Penalty Relief Deadline Approaching for MEPs
On July 24, 2019, the Department of Labor (the “DOL”) issued Field Assistance Bulletin 2019-01 (the “Bulletin”), which provides transition relief to multiple employer plans (“MEPs”) that failed to comply with certain annual reporting requirements. The Bulletin focuses on a … Continue reading
Posted in Employee Benefits, Qualified Retirement Plans
| Tagged compliance, Form 5500, MEP, multiple employer plan, participating employer, transition relief
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Reassigning Section 1557: Trump Administration Proposes Reversal of Transgender Benefits Rule
In 2016, the Department of Health and Human Services (“HHS”) Office of Civil Rights issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act (“Section 1557”), which prohibit the categorical refusal of health coverage to transgender participants and … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 1557, ACA, EEOC, HHS, transgender, transgender benefits, Trump
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