You received your 408(b)(2) disclosures from your covered service providers. Have you looked at them? Do you know what you are looking at? Do you know what you are supposed to do next?
In this ALERT we will focus on the plan sponsor’s responsibility with respect to the covered service provider (CSP) fee disclosures. MORE
2012 archive, 408 (b) (2), Disclosure, DOL, Fee Transparency, Plan FeesErisaALERT© The IRS recently issued Notices 2012-58 and 2012-59. Notice 2012-58 addresses the determination of full-time employee status for purposes of shared responsibility. Notice 2012-59 addresses the 90 day waiting period requirements. This Alert summarizes important points in each notice and provides a to-do list for plan sponsors. Notice 2012-58 will be of particular interest […]
2012 archive, 90 day waiting period, ACA, DOL Technical Release, ERISA, Notice 2012-58, Notice 2012-59In this ALERT we will focus on the plan sponsor’s responsibility to provide fee disclosures to participants in participant directed individual account plans (except SEPs, IRAs, SIMPLEs and governmental plans) by August 31st. The ball is now in the plan sponsor’s court and it is getting close to the end of the overtime period We […]
2012 archive, 404(a)(5), Disclosure, Participant disclosuresErisaALERT 2011-16 described the guidance regarding Medical Loss Ratio (MLR) rebates. Since that ALERT was issued the IRS has issued guidance FAQs regarding the tax treatment of the MLR rebates. Many plan sponsors have recently received letters from their insurance companies indicating that a check will be in the mail. Insurance companies have sent letters […]
2012 archive, ACA, minimum loss ratio, MLRThe Affordable Care Act imposes fees on issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans. The fees are generally referred to as the comparative effectiveness research fees. The IRS recently issued proposed regulations regarding the fee. This ALERT will focus on employer sponsored group health plans. Bottom Line: The […]
2012 archive, ACA, CER, comparative effectiveness research fee, PCORIIn recent court case,Tussey v. ABB, Inc., No. 2:06-CV-04305-NKL (W.D. Mo., Mar. 31, 2012), the judge found that the plan fiduciaries breached their fiduciary duties and were jointly and severally liable for $13.4 million lost by the Plan due to failure to monitor recordkeeping fees and negotiate rebates and $21.8 million lost by Plan due […]
2012 archive, DOL, Fiduciaries, Fiduciary, fiduciary breachIn recent weeks the DOL has issued a number of notices to plan sponsors for both retirement and health & welfare plans. Retirement plans – the notices relate to Form 5500 filings. These notices relate to the information reported on the Schedule H vs the information reported on the Schedule C. Specifically, plans that report […]
2012 archive, DOL, DOL auditsOn March 19, 2012 the IRS, DOL and HHS jointly issued Frequently Asked Questions (FAQs) Affordable Care Act Implementation (Part VIII) regarding the implementation of the Summary of Benefits and Coverage (SBC) requirements under the Affordable Care Act Implementation (Part VIII of the Act). We provided an extensive description of the proposed SBC regulation in […]
2012 archive, ACA, SBCThe IRS, DOL and HHS jointly published final regulations regarding the Summary of Benefits and Coverage and Uniform Glossary as well as other guidance regarding the SBC in February. The regulations indicate that this guidance is for the first year of applicability and the Departments intend to issue updated material for later years. You can […]
2012 archive, ACA, SBCThe IRS issued guidance regarding lifetime income options to help participants structure their retirement plan distributions to help ensure that they don’t run out of money. The guidance includes: A revenue ruling clarifying rules for defined contribution plans that offer lifetime income options, A revenue ruling clarifying rules that apply to rollovers into defined benefit […]
2012 archive, IRS, lifetime security, longevity annuity contract(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business