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November 9, 2010
Plan Communication Important
In a recent case (Madhuri Kasireddy, Plaintiff, v. Bank of America Corporation Corporate Benefits Committee,No. 09C7940, US District Court, N.D. Illinois, Eastern Division, 10/13/10),the importance of diligence in plan communication is underscored.
Participant Level Fee Disclosure Regulations Finalized
The DOL’s Employee Benefit Security Administration (EBSA) has been engaged in a 3-prong approach to ensure adequate fee disclosures payable by retirement plans. The first prong came in the form of Schedule C reporting requirement; these requirements took effect for the 2009 plan year. The second prong relates to fee disclosure to plan sponsors. On July 16, 2010, the DOL issued interim final regulations addressing fee disclosure matters by service providers (see Retirement Plan Fee Disclosure Continuum, Benefit Beat, 8/5/10). The third prong relates to participant level fee disclosures. On October 20, 2010, EBSA issued final regulations, a Fact Sheet, and a Model Chart, relating to participant level fee disclosure.
2011 limits applicable to MSAs, LTC premium, adoption assistance programs and Social Security
In Revenue Procedure 2010-40, the IRS released 2011 limits relating to MSAs, LTC premium, adoption assistance programs, and Social Security wage base. Following are amounts applicable to tax years beginning in 2011. Please note that the 2011 annual limits applicable to health savings accounts were released earlier this year (see No Change in Cost of Living Adjustments for HSAs,Benefit Beat, 6/7/10).
October 15, 2010
Highlights of the Small Business Jobs Act
On September 27, 2010, President Obama signed the Small Business Jobs Act of 2010 (“SBJA”, P.L. 111-240). This law includes a couple of provisions, specific to employee benefit plans. Following are highlights of this new law:
Notice Reminders: Medicare Part D
October 12, 2010
HRB 23 - Agencies Issue PPACA Clarifications
HRB 22 - Limited PPACA Exemption for Self-Funded, Non-Federal Governmental Plans
October 5, 2010
HRB 21 - Early Retiree Reimbursement Program Updates
September 21, 2010
HRB 20 - Mini-Med Plan Relief from Annual Limit Restriction Offered
September 9, 2010
IRS COBRA Subsidy FAQs Updated
Recently, the IRS has updated its FAQs relating to the COBRA subsidy (note Q&As AE-36 and AE 38-50). The COBRA subsidy, enacted originally on February 17, 2009, and extended several times, expired on May 31, 2010.