The IRS issued Notice 2020-76 which once again extends the due date for certain information returns under IRC6055 and 6066. A brief recap of the filing requirements: Due date Extended due date Forms 1095-C and 1095-B Statements to Individuals February 1, 2021 March 2, 2021 Submission to the IRS February 28, 2021(paper)March 31, 2021 (iffiled […]
6056, ACA, compliance; 6055, Disclosure, ReportingThe CARES Act was signed into law on March 27, 2020. Some guidance has been issued but more guidance isneeded in many areas, so we are keeping this ALERT simple. The provisions are effective immediately. Someprovisions are of limited duration. It remains to be seen if the restrictions will change. Provision Change Act Section Effective […]
401(k), Cafeteria Plan, DOL, IRSFurther Consolidated Appropriations Act, 2020 was enacted on December 20, 2019. It is comprised of various “Divisions”. Division N is Health and Human Services Extenders which includes repealing certain ACA provisions and Division O is Setting up Every Community Up for Retirement Enhancement (SECURE) which impacts retirement plans. This ALERT will briefly summarize items of […]
ACA, Affordable Care Act, IRSThe IRS issued Notice 2019-63 which once again extends the due date for certain information returns under IRC 6055 and 6066. A brief recap of the filing requirements: Due date Extended due date Forms 1095-C and 1095-B Statements to individual January 31, 2020 March 2, 2020 Submission to the IRS February 28, 2020 (paper) March […]
ACA, Disclosure, ReportingMany plan sponsors face the issue of what to do with uncashed checks. Even if the check is sent to the correct address, the participant or former participant may not cash the check. The IRS issued a Revenue Ruling (Revenue Ruling 2019-19 – Failure to Cash a check From a Qualified Plan) which might influence […]
401k, distributions, IRS, uncashed checksThe Affordable Care Act added IRC sections §6055 and §6056 which requires insurers, applicable large employers and self-insured plans to provide annual health information returns to the IRS and statements to employees. (See ErisaALERTs 2014-04 and 2014-09 for background information.) The regulations require that the employee statements be provided by January 31 and reported to […]
6055, 6056, ACA, compliance, reporting and disclosureIn 2015, the IRS announced that it was eliminating the five year remedial amendment cycle for individually designed plans and that determination letters for such plans would only be available for initial plan qualification and as permitted by the IRS. Earlier this year, the IRS announced that determination letters for individually designed plans would no […]
compliance, Determination Letter, Qualification408(b)(2) disclosures for retirement plans have been in effect for a few years. It is important to remember that the final regulations reserved a section for welfare plan disclosure. The preamble to the final regulations noted that commenters to the regulations supported disclosures specifically tailored to welfare plans. Although somewhat dated, the Employee Benefits Security […]
401k, 401k fees, fee disclosure, Form 5500, health & welfareErisaALERT 2014-11 – What is the transitional reinsurance fee? The Affordable Care Act established a three-year (2014, 2015 and 2016) transitional reinsurance program to stabilize premiums in the individual market inside and outside of the Marketplaces. Who must pay the transitional reinsurance fee? A contributing entity must make reinsurance contributions on behalf of its enrollees […]
ACA, compliance, HCR, transitional reinsurance feeErisaALERT 2014-10 – What is an HPID? Note: Late on October 31, HHS announced a delay HPID requirement. A health plan identifier (HPID) is intended to increase standardization within HIPAA standard transactions. Both the Affordable Care Act and the Social Security Act require the adoption of a standard unique health plan identifier. Covered entities are […]
ACA, Affordable Care Act, HCR, Health Plan Identifier, HPID(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business