Legislative & Regulatory Updates

What's New in Claims Procedures for Disability Benefits

The Department of Labor issued a final rule on December 16, 2016 that amends the claims procedure regulation for disability benefits claims. The aim of the new rule is to give disability benefit claimants the same level of procedural protections that group health benefit claimants have after the enactment of the Affordable Care Act.

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2016 Required Amendments List is a List of One

On December 13, 2016, the Internal Revenue Service ("IRS") issued the 2016 list of required amendments. This list is the first of the promised annual required amendment lists ("RA List") pursuant to Revenue Procedure 2016-37, which ended the cyclical determination letter program for individually designed plans.

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Temporary Halt to Overtime Rule Regulations

On November 22, 2016, a federal judge issued a preliminary injunction that temporarily blocks the new overtime regulations on a national basis that were scheduled to take effect on December 1, 2016.

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Good News! – But Stay the Course – IRS Notice 2016-70 Provides Reporting Extension Under Codes 6055 of the Internal Revenue Code

The Department of Treasury and IRS have extended, by 30 days, the due date to furnish the 2016 Form 1095-B and the 2016 Form 1095-C, to March 2, 2017.

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Patient-Centered Outcomes Research Institute (PCORI) Fees Update

The IRS has published the new fee that will be applicable for policy years and plan years that end on or after October 1, 2016 and before October 1, 2017. That new fee, which is assessed and calculated using the average number of lives (includes spouses and dependents) covered under the policy, is $2.26 per covered life.

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Reminder to Pay Transitional Reinsurance Program Fees

If you paid the 2015 Transitional Reinsurance Fee of $44 per member (applies to both employee and covered dependents) in installments, the 2nd installment of $11 per member is due November 15, 2016.

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Hurricane Matthew Victims Get a Helping Hand from the IRS

The Internal Revenue Service (IRS) announced on October 21, 2016 that participants in 401(k) plans, 403(b) tax-sheltered annuities and 457(b) deferred compensation plans may be able to use newly announced streamlined rules to alleviate the financial hardships caused by Hurricane Matthew with loans and hardship distributions.

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Correction Program No Longer A Puzzle in Pieces for Retirement Plan Sponsors

The new procedure for the Employee Plans Compliance Resolution System (EPCRS) will make it easier and clearer for retirement plan sponsors to correct plan failures so that the plans can continue on a tax-favored basis.  Parts of EPCRS had been in three separate revenue procedures, and the new Determination Letter program had confused other portions of EPCRS.  Now, there is more clarity, and it's in one place.

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PBGC Issues Final Regulations on Section 4010 Filings for Unfunded Plans

The PBGC has issued an updated set of rules regarding ERISA 4010 reporting.

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October 14 Deadline - Medicare Part D Notice

It's that time of year again when employers must comply with notifying Medicare-eligible members covered under employer-sponsored health plans whether their prescription drug (Rx) benefits qualify as "creditable coverage" under Medicare Part D. The Medicare Part D Notice is due by October 14, 2016.

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A Taxpayer Win - Self-Certification for Waiver of the 60-day Rollover Limit
On August 24, 2016, the IRS issued Revenue Procedure 2016-47, which provides that an individual taxpayer can self-certify that they are eligible for a waiver of the 60-day rollover requirement by using the model letter provided in the Revenue Procedure.

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