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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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Much Ado about $50… IRS Announces Relief for Reduction of Maximum HSA Contributions
On April 3, we blogged about a reduction in the HSA contribution limit for family coverage in 2018 from $6,900 to $6,850. This was a technical change resulting from the Tax Cuts and Jobs Act that adjusted the method for calculating inflation. On April 26, in Revenue Procedure 2018-27, the IRS came through with a fix for this $50 technical issue. For 2018, taxpayers with family coverage under a high deductible health plan (HDHP) may treat $6,900 as the maximum deductible HSA contribution.
Posted in Employee Benefits, Health & Welfare Plans
| Tagged Contribution limit, HSA, revenue procedure 2018-27
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IRS Announces 2018 Cost of Living Adjustments
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This post has been updated as of June 7, 2018, to reflect the revised maximum annual HSA contribution limit for family coverage set out in Revenue Procedures 2018-18 and 2018-27. The IRS recently announced cost-of-living adjustments for 2018 in Notice 2017-64 and related guidance. The key dollar limits for qualified retirement plans and health and welfare plans are noted below. Qualified Retirement Plan Dollar Limits |
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| 2017 | 2018 | |
| Limit on Section 401(k) deferrals (Section 402(g)) | $18,000 | $18,500 |
| Dollar limitation for catch-up contributions (Section 414(v)(2)(B)(i)) | $6,000 | $6,000 |
| Limit on deferrals for government and tax-exempt organization deferred compensation plans (Section 457(e)(15)) | $18,000 | $18,500 |
| Annual benefit limitation for a defined benefit plan (Section 415(b)(1)(A)) | $215,000 | $220,000 |
| Limitation on annual contributions to a defined contribution plan (Section 415(c)(1)(A)) | $54,000 | $55,000 |
| Limitation on compensation that may be considered by qualified retirement plans (Section 401(a)(17)) | $270,000 | $275,000 |
| Dollar amount for the definition of highly compensated employee (Section 414(q)(1)(B)) | $120,000 | $120,000 |
| Dollar amount for the definition of a key employee in a top-heavy plan (Section 416(i)(1)(A)(i)) | $175,000 | $175,000 |
| Dollar amount for determining the maximum account balance in an ESOP subject to a five-year distribution period (Section 409(o)(1)(C)(ii)) | $1,080,000 | $1,105,000 |
| SIMPLE retirement account limitation (Section 408(p)(2)(E)) | $12,500 | $12,500 |
| Social Security Taxable Wage Base | $127,200 | $128,700 |
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Health and Welfare Plan Dollar Limits |
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| 2017 | 2018 | |
| Annual Cost Sharing Limit (self-only coverage) | $7,150 | $7,350 |
| Annual Cost Sharing Limit (other than self-only coverage) | $14,300 | $14,700 |
| HDHP Out-of-Pocket Maximum (self-only coverage) | $6,550 | $6,650 |
| HDHP Out-of-Pocket Maximum (family coverage) | $13,100 | $13,300 |
| Annual HDHP Deductible (self-only coverage) | Not less than $1,300 | Not less than $1,350 |
| Annual HDHP Deductible (family coverage) | Not less than $2,600 | Not less than $2,700 |
| Maximum Annual HSA Contributions (self-only coverage) | $3,400 | $3,450 |
| Maximum Annual HSA Contributions (family coverage) | $6,750 | $6,900* |
| Maximum HSA Catch-Up Contribution | $1,000 | $1,000 |
| Health Flexible Spending Account Maximum | $2,600 | $2,650 |
* The maximum annual HSA contribution for family coverage was reduced from $6,900 to $6,850 by Revenue Procedure 2018-18. Read More ›
Posted in Employee Benefits, Health & Welfare Plans, Qualified Retirement Plans
| Tagged COLA, cost of living adjustment, defined benefit, defined contributino, ESOP, FSA, HDHP, health and welfare, HSA, key employee, maximum\, qualified retirement, simple
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What is Telemedicine? A Cool Benefit or a Hot Mess?
We’ve had numerous inquiries lately about telemedicine benefits. My clients most typically ask either “is this a group health plan?” or “is it just access to another provider?” Clearly, there is much confusion surrounding telemedicine benefits. Part of the problem is that the regulators have yet to issue guidance on how telemedicine should be treated. All we can do is take what is a very innovative benefit and figure out how it fits into a complicated, and sometimes outdated, regulatory framework.
Let’s start by agreeing that telemedicine benefits are pretty cool. With telemedicine, employees can usually see a doctor sooner than if they had to go to a doctor’s office. Read More ›
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged EAP, employee assistance program, ERISA, Excepted Employee Assistance Program, group health plan, health plan, healthcare, HSA, Notice 2004-50, telemedicine, voluntary plan safe harbor
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IRS Announces 2016 Health FSA, HSA, HDHP and Transportation Plan Limits
The IRS has announced cost of living adjustments for health flexible spending accounts (“health FSAs”) in Section 125 cafeteria plans, contributions to health savings accounts (“HSAs”), out-of-pocket maximums under high deductible health plans (“HDHPs”) and qualified transportation plan benefits for 2016.
For 2016, the health FSA limit on voluntary employee salary reduction contributions will remain $2,550 (unchanged from 2015). For 2016, the HSA contribution limit for individuals will remain $3,350 (unchanged from 2015). For families the HSA contribution limit for 2016 is $6,750 (increased from the 2015 limit of $6,650). For 2016, the HDHP out-of-pocket maximum for individuals is $6,550 (increased from the 2015 limit of $6,450). Read More ›
Posted in Employee Benefits, Health & Welfare Plans
| Tagged contribution limits, Health FSA, HSA, IRS, out-of-pocket maximum, parking, qualified transportation, transit pass
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Carryover Confusion: Chief Counsel Clears Up Rules on Health FSA Carryovers
Earlier this year, I blogged about how the IRS modified the health flexible spending account (“health FSA”) “use-it-or-lose-it” rule to allow carryovers of up to $500 to subsequent plan years. This rule change caused some confusion. Employers were asking, “what happens to an employee’s eligibility to contribute to a health savings account (“HSA”) if they have a carryover from a general purpose health FSA?” The answer was that because a general purpose health FSA is considered “other coverage,” participation in a general purpose health FSA renders an individual ineligible to contribute to a HSA. But employers still needed guidance on ways to handle health FSA carryovers for employees who also wanted to contribute to a HSA in the following year. Read More ›
Posted in Employee Benefits, Health & Welfare Plans
| Tagged Carryover, HDHP, Health FSA, HSA, IRS, Use-it-or-Lose-it
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