President Biden announced that the COVID-19 Public Health Emergency (PHE) and the National Emergency declared by President Trump in 2020 will end on May 11, 2023. The PHE relief issued in response to the pandemic affected group health plan coverage requirements related to COVID-19 prevention and treatment. The National Emergency relief suspended deadlines that
Suzanne G. Odom
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SECURE 2.0 Series Part 1: More Roth, More Catch-Up, and Catch-Up As Roth
By Suzanne G. Odom on
The SECURE 2.0 Act of 2022 (SECURE 2.0) contains several provisions that allow the federal government to have its cake (more tax dollars) and eat it too (more retirement savings, easing Social Security challenges). With SECURE 2.0, we find more Roth, more catch-up, and catch-up as Roth.
More Roth
Named after the late Delaware Senator…
SECURE (2.0) At Last!
By Suzanne G. Odom on
Posted in Consolidated Appropriations Act, SECURE 2.0
On December 29, 2022, President Biden signed the Consolidated Appropriations Act, 2023, a massive omnibus spending bill that will keep the government funded through the end of its September 30, 2023, fiscal year. Included in Division T of the Act is the bipartisan legislation dubbed the SECURE 2.0 Act of 2022 (SECURE 2.0). Containing voluminous…
4th Quarter 2022 Quick Hits for Plan Sponsors and Administrators
By Suzanne G. Odom & Alec Nealon on
Posted in 401(k) plan, ACA, Affordable Care Act, Amendments, CARES Act, Consolidated Appropriations Act, coronavirus, Employee Health & Welfare Plans, Employer Health and Welfare Plan, ERISA, hdhp, HRA, hsa, IRS Guidance, pharmacy benefit Manager, Prescription Drug and Healthcare Spending, Retirement plans, RISE and SHINE Act, SECURE 2.0, SECURE Act
As we enter the fourth quarter of 2022, sponsors and administrators of employee benefit plans have a lot to juggle. From open enrollment and required notices to plan document deadlines, it is a busy time of year. Yet, there always seems to be something new to add to the mix. This year is no different. …
Do Employers Now Have to Offer Affordable Family Coverage?
By Suzanne G. Odom on
In furtherance of the Biden Administration’s January 28, 2021, Executive Order 14009 and April 5, 2022, Executive Order 14070 to protect and strengthen the ACA, the Treasury Department and IRS published a proposed rule on April 7, 2022, advancing an alternative interpretation of Internal Revenue Code Section 36B. Employers can breathe a sigh of relief…
2021 Plan Amendment Deadlines and Other Looming Fourth Quarter Considerations
By Suzanne G. Odom & Joy M. Napier-Joyce on
As the year draws to a close, it is helpful for employers to pause to evaluate employee benefit plan amendment deadlines and other crucial fourth-quarter considerations, including: More…
IRS Answers to Your American Rescue Plan Act COBRA Subsidy Questions
In much-anticipated guidance, the Internal Revenue Service has offered its insight on the implementation of the COBRA temporary premium subsidy provisions of the American Rescue Plan Act of 2021 (ARPA) in Notice 2021-31.
Spanning more than 40 pages, the IRS-answered frequently asked questions (FAQs) finally resolve many issues relating to temporary premium assistance for…
Remote Employees: The Geographic Tax and Benefits Challenges
By Suzanne G. Odom & Raymond P. Turner on
As the COVID-19 vaccine has become readily available, and many employers contemplate employees returning to the office to work, both employers and employees have accelerated demands for new and permanent remote work location arrangements for a variety of jobs. Employers across the country are revisiting their business strategies, employment policies, and related legal and tax…
About That Pension Check… A Miscalculation Case With Broader Implications
By Craig A. Day & Suzanne G. Odom on
The Ninth Circuit Court of Appeals recently addressed several issues of first impression in Bafford v. Northrop Grumman (9th Cir. April 15, 2021), a lawsuit involving retirees who received vastly overstated pension benefit estimates from the plan’s recordkeeper reminds employers of the importance of careful administration. The case highlights the need to ensure that…
American Rescue Plan Act of 2021: COBRA Subsidy, Pension Funding, and Other Employee Benefit Changes
The American Rescue Plan Act of 2021 (ARPA) is the latest federal COVID-19 relief bill, which the President signed into law on Thursday, March 11, 2021. ARPA includes new COBRA continuation coverage election, notice, and subsidy requirements; pension plan funding relief; and some cost-saving benefit opportunities employees may be able to leverage. Some of these…