Publication
SW Benefits Update – COVID-19 and Cafeteria Plans: To Amend or Not to Amend?
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By Allison B. Bans On May 12, the IRS issued Notice 2020-29 “COVID-19 Guidance Under Section 125 Cafeteria Plans and Related to High Deductible Health Plans” and Notice 2020-33 “Section 125 Cafeteria Plans – Modification of Permissive Carryover Rule for Health Flexible Spending Arrangements and Clarification Regarding Reimbursements of Premiums by Individual Coverage Health Reimbursement Arrangements.” As explained in more detail below, Notice 2020-29 provides increased flexibility for cafeteria plans in response to the COVID-19 pandemic and Notice 2020-33 increases the health flexible spending arrangement (“Health FSA”) carryover limit and clarifies the ability of a health plan to reimburse individual insurance policy premium expenses incurred prior to the beginning of the plan year. |
About Snell & Wilmer
Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 17 locations throughout the United States and in Mexico, including Los Angeles, Orange County, Palo Alto and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
