The IRS issued Announcement 2011-21 which designated the Form 8955-SSA as the form to use for reporting separated participants with deferred vested benefits. The IRS has released a draft of Form 8955-SSA as well as posted FAQs on their website. Previously, Schedule SSA was used to report separated participants with deferred vested benefits until the […]
8955 SSA, Disclosure, Form 5500, Form 8955 SSA, IRSRequest for Information Regarding Electronic Disclosure by Employee Benefit Plans The DOL has asked 30 questions seeking to obtain views and suggestions regarding electronic disclosure. The DOL previously provided a safe harbor for electronic distribution in 2002. The IRS also issued guidance regarding electronic distribution in 2006. The SEC has provided guidance on the electronic […]
Disclosure, DOL, electronic disclosureIn this ALERT we continue summarizing recent government guidance/announcements. Form W-2 Reporting The Affordable Care Act required informational reporting regarding the aggregate cost of employer sponsored group health plan coverage to be included in W-2s and was originally scheduled to be effective with the 2011 calendar year. Notice 2010-69 provided transition relief until 2012 although […]
ACA, w-2 reportingIn this ALERT we continue summarizing recent government guidance/announcements. Automatic Enrollment in Large Employer Health Plans Recall that Health Care Reform contained a provision requiring automatic enrollment for large employers with more than 200 full-time employees. There were varying interpretations of when this provision would take effect. EBSA recently announced that it is hosting a […]
ACA, automatic enrollment, claims appeals, CLASS ActIn Announcement 2011-21, the IRS announced that Form 8955-SSA, a stand- alone form to be filed with the IRS, is the successor to the Schedule SSA (Form 5500). Form 8955-SSA is used to report terminated participants with deferred vested benefits. For 2009 and 2010 plan years, the Form 8955-SSA is due the later of the […]
8955, Form 5500, Form 8955 SSA, IRS, ReportingIn this ALERT we are going to continue summarizing key government guidance issued over the past two months. It may be old news to some but hopefully will serve as a reminder. DOL FAQs As you are probably aware, the DOL has published a number of FAQs, the most recent being FAQ Part V. Two […]
ACA, automatic enrollment, SBCThere has been a lot of government guidance lately; we thought we would summarize just a few items in this ALERT as well as remind you of some action you might have to take soon! Plans that obtained waiver of annual limit rules – February 7, 2011 deadline for certain plans. As a condition of […]
ACA, creditable coverage to CMS, ndt, Nondiscrimination testingOn October 21, 2010, EBSA issued proposed regulations expanding the definition of fiduciary. Investment Advisors and service providers will have to examine the proposed rules to determine whether they fall under the broadened definition. The DOL is requesting comments by January 20, 2011. This ErisaALERT will provide a very brief overview of some of the […]
In 2008, we issued a series of ErisaALERTs discussing the proposed regulations regarding fee transparency (Plan participants, Reasonable Contract, 2009 Schedule C). The Obama administration delayed finalization of the regulations pending review. In July 2010 we issued an ErisaALERT discussing the Reasonable Contract interim final regulations. In this ErisaALERT, we will cover the final regulation […]
404(a)(5), defined contribution, ERISA, participant disclosureReasonable Contract under ERISA 408(b)(2) Disclosure Requirements In 2008, we issued a series of ErisaALERTs discussing the proposed regulations regarding fee transparency (Plan participants, Reasonable Contract, 2009 Schedule C). The Obama administration delayed finalization of the regulations pending the new administration’s review. The wait is over; interim final regulations regarding the Reasonable Contract were issued […]
408b2, Disclosure, ERISA, reasonable contract(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business