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Business Insights, Research & Perspectives

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November 5, 2007

Medicare Part D Notice: Don't Forget!

  • Annual Medicare Part D Notices . The annual notices of creditable and noncreditable coverage to Medicare-eligibles must be providedno later than November 14, 2007.  Notices to be used on or after February 15, 2007, as well as Creditable Coverage Guidance, are all available on-line from the CMS website.
  • Disclosure Notice to CMS.  An annual report must also be submitted to CMS describing whether the prescription drug coverage is creditable or not creditable.  This filing must be accomplished electronically, and is due within 60 days of the commencement of the plan year.  CMS has recently revised its guidance, including Form Instructions and Screen Shots, on how this disclosure notice must be provided to them.

 

November 5, 2007

PPA Notices Re-visited

Qualified Default Investment Alternatives

November 5, 2007

Delay of 409A Implementation

The IRS recently issued Notice 2007-86, which extends thedeadline for compliance with 409A rules until December 31, 2008.

November 5, 2007

2008 Cost of Living Adjustments

2008 Retirement Plan COLAs

October 9, 2007

Medicare Premiums and Deductibles for 2008

The Centers for Medicare and Medicaid Services have released the Medicare premium and deductible amounts for 2008.

October 9, 2007

409A Documentation Limited Relief

409A is a tax code regulating nonqualified deferred compensation. It was enacted in October 2004, and the time for compliance is upon us. Generally, nonqualified deferred compensation plans must comply with the 409A rules beginning January 1, 2008, or risk substantial penalties, both to participant and employer.

October 9, 2007

Health Care Reform and the 2008 Presidential Campaign

As the Presidential campaign begins to heat up, the candidates are sharpening their pencils in designing health care reform proposals. While it is far too early to surmise how these proposals might be sculpted, there are a couple nonpartisan websites that are following the candidate’s proposals, such as Kaiser Family Foundation’s health08.org and its list of resources, as well as the New York Times.

October 9, 2007

Time Now for New Massachusetts Filings by Employers

The Massachusetts health care reform law passed last year requires employers who employ 11 or more full-time equivalent employees in the Commonwealth to accomplish certain filings between October 1st and November 15th of each year. The first filing period is upon us.

September 11, 2007

Dependent Child Conundrum

In the very recent past, and particularly in 2007, many State Legislatures have found it to be in their collective wisdom to amend State insurance laws as they relate to the definition of dependent child. In large part, the definition of dependent child, for health insurance purposes only, has been expanded. It appears that States are attempting to narrow the gap of their uninsured population. Young people, particularly those recently out of school, are a significant portion of the uninsured population. The theory goes that allowing these children to stay on their parents’ plan for longer period of time will reduce the uninsured population.

August 7, 2007

403(b) Plans: ERISA Exemption?

One of the questions that has been nagging tax-exempt organizations is how to preserve a plan’s exemption from ERISA. Generally, not-for profit organizations sponsoring 403(b) plans are subject to ERISA, unless the plan is fully funded with employee money, and as long as certain other conditions are met. With the issuance of the new 403(b) regulations, a question has arisen about how an employer can make an employee-funded plan available that would be exempt from ERISA? The day after the final 403(b) regulations were issued, the DOL’s Employee Benefits Security Administration came out with Field Assistance Bulletin (FAB) 2007-02 to give direction on this question.

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