June, 2008 The Auditors have arrived! ERISA audits will be more intense this year due in part to Statement on Accounting Standards (SAS) No. 104-111 which deal with Risk Assessment Standards. The Statements are effective for periods beginning on or after December 15, 2006; early adoption was permitted. These Standards provide guidance for the auditors […]
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ErisaALERT 2007-05 DOL Auditing Medical Plan
December, 2007 DOL Auditing Medical Plan The Department of Labor (DOL) is starting to audit health plans!!! We are currently working with a client in responding to a DOL audit notice. Relying on that old adage “forewarned is forearmed”, we would like to share with you the data that the DOL is requesting in this […]
DOL, DOL audits, DOL plan audits, H&W plan auditsErisaALERT 2007-04 Administrative and procedural implications of the QDIA regulations
November, 2007 Focusing on the administrative and procedural implications of the QDIA regulations By now you have received numerous bulletins from your consultants and attorneys regarding the new qualified default investment alternative (QDIA) rules. In this ErisaALERT we will try very hard not to repeat everything you have already received, but rather focus on the […]
401k, defined contribution, QDIAErisaALERT 2007-03 IRS Issues Proposed Cafeteria Plan Regulations
IRS Issues Proposed Cafeteria Plan Regulations
WHAT IS IT?: – On August 3, 2007 the IRS issued proposed regulations on Cafeteria Plans. With one exception regarding life insurance, the regulations are effective January 1, 2009. Comments on the proposed regulations are due November 5th with hearings to be held on November 15th. MORE
Cafeteria Plan, H&W, health & welfare, ndt, Nondiscrimination testingErisaALERT 2007-02 It is a Matter of Focus (or how to get through your stack of professional reading)
March, 2007 It is a Matter of Focus (or how to get through your stack of professional reading) WHAT IS IT? –This issue of ErisaALERT is a departure from the usual format of our ErisaALERTS which generally focus on issues related to recent government guidance. Recently I decided to go through my ever growing stack […]
401k fees, auto enrollment, investment advice, periodic benefit statementsErisaALERT 2007-01 DOL Issues Guidance on Periodic Benefit Statements
January, 2007 DOL Issues Guidance on Periodic Benefit Statements WHAT IS IT?: – In December 2006, the DOL issued Field Assistance Bulletin (FAB) No. 2006-03 regarding the periodic benefit statement requirement contained in the Pension Protection Act of 2006 (PPA). Plan sponsors should act in good faith compliance until regulations are issued concerning the pension […]
benefit statements, DOL, FAB 2006-03, periodic benefit statementsErisaALERT 2006-06 FSAHRA Debit Cards
August, 2006 IRS Issues Guidance on the use of debit/credit cards in Health FSAs and HRAs WHAT IS IT: In July 2006, the IRS issued Notice 2006-69 providing additional guidance regarding the use of debit cards, credit cards and stored value cards to reimburse participants in self-insured medical reimbursement plans, such as health flexible spending […]
debit cards, FSA, HRA, IRSErisaALERT 2006-05 Dependent Care Expenses
June, 2006 IRS Proposed Regulations on Dependent Care Expenses WHAT IS IT: In May 2006, the IRS issued proposed regulations under IRC Section 21 relating to the dependent care tax credit. The proposed rules renumber, restructure and are intended to improve clarity of regulations that were written over 20 years ago. The new proposed regulations […]
DCAP, Dependent care expenses, FSAErisaALERT 2006-04 HIPAA Enforcement
March, 2006 Small Health Plans Must Comply With HIPAA Security Rules by April 20, 2006 WHAT: The HIPAA Security Rule applies to all electronic protected health information (ePHI) created, received, maintained or transmitted by a covered entity. Covered entities are required to implement reasonable and appropriate security measures to protect against reasonably anticipated threats or hazards […]
compliance, enforcement, HIPPAErisaALERT 2006-02 Creditable Coverage Disclosure to CMS
March, 2006 Creditable Coverage Disclosure to CMS WHAT IS IT: Most employers that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to Centers for Medicare & Medicaid Services (CMS) whether the coverage is “creditable prescription drug coverage”. This disclosure is required whether the coverage is primary or secondary to Medicare. Coverage […]
CMS, creditable coverage, Reporting