Legislative & Regulatory Updates

Numerous Hikes for HSA and HDHP Limits

On May 4, 2017, the Internal Revenue Service announced in Revenue Procedure 2017-37 the 2018 limits for contributions to Health Savings Accounts (HSAs) and definitional limits for High Deductible Health Plans (HDHPs).

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ACA Fees Still Apply: Patient-Centered Outcomes Research Institute (PCORI) Fee Payment Is Due July 31st

While the American Health Care Act (AHCA) was passed by the House of Representatives, the Affordable Care Act (ACA) is still in effect and as such, the applicable PCORI fees are to be paid by July 31, 2017. 

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House Passes American Health Care Act: So Now What?

Eventually we may see the AHCA enacted with a few minor changes, or it may be a very different looking repeal and replace piece of legislation. Therefore, at this moment in time, employers and plan sponsors must recognize that the ACA is still the law of the land, and they should continue to act accordingly under all current ACA requirements.

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The 2017 Operational Compliance List - A Promised Tool from the IRS

The Internal Revenue Service (IRS) handed sponsors of individually designed plans the second of two annual compliance tools on February 27, 2017, when it published the Operational Compliance List on its website.

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IRS: Forfeitures can fund QNECs and QMACs

On January 18, 2017, the Internal Revenue Service ("IRS") issued proposed regulations that amend the definitions of qualified matching contributions ("QMACs") and qualified nonelective contributions ("QNECs") so that they can be funded with plan forfeitures.

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Proposed New Funding Mortality Rates

On December 28, 2016, the IRS issued proposed regulations with new required mortality rates for defined benefit pension plans for funding purposes, effective starting in 2018. The proposed regulations don't address the mortality required for minimum lump sum calculations, but it is expected that the IRS will propose a unisex version of the new rates that will be effective in 2018 as well.

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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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