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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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The IRS Retirement Plan Determination Letter Program – The IRS Taketh and Then Giveth (Some Transition Guide)
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 … Continue reading
Posted in Employee Benefits, Qualified Retirement Plans
| Tagged Cycle A, determination letter, IRS
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HIPAA “Phase 2” Audits: Are You Ready?
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged HIPAA, HIPAA audit, HIPAA training, privacy and security policies
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November 5 Deadline to Obtain HPID Delayed by HHS
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged health plans, HIPAA, HPID
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HIPAA Business Associates Agreements – Reminder of September 22 Deadline
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged business associate agreements, Health Care, health plans, HHS, HIPAA, Privacy Rule, Security Rule, welfare plans
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Employers May Be Able to Exempt Severance Payments from FICA Tax under Quality Stores
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 … Continue reading
Posted in Employee Benefits
| Tagged FICA, severance, SUB payments, Supreme Court, U.S. v. Quality Stores
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