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

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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

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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

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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

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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

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