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Kellie M. ThomasBlog Posts

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Pre-Thanksgiving ACA Reporting Relief That’s No Turkey

Just three weeks ago, we wrote that employers likely would not receive certain Affordable Care Act reporting relief to which they’ve become accustomed. But in a welcome turn of events, the IRS just released proposed regulations that make permanent a 30-day automatic extension for furnishing Forms 1095-B and 1095-C to individuals.  Such forms will now...
November 24, 2021

The Pandemic Continues, but ACA Reporting Relief Does Not

As employers with 50 or more full-time (or full-time equivalent) employees are well aware, the Patient Protection and Affordable Care Act (”ACA”) requires annual submission of Forms 1094-C and 1095-C with the Internal Revenue Service, and distribution of Forms 1095-C.  These submissions and distributions are generally due:  Furnishing of Forms 1095-C to employees: January 31... Continue Reading…
November 10, 2021

The Pandemic Continues, but ACA Reporting Relief Does Not

As employers with 50 or more full-time (or full-time equivalent) employees are well aware, the Patient Protection and Affordable Care Act (”ACA”) requires annual submission of Forms 1094-C and 1095-C with the Internal Revenue Service, and distribution of Forms 1095-C.  These submissions and distributions are generally due:  Furnishing of Forms 1095-C to employees: January 31...
November 4, 2021

The End of a (Short) Era: ARPA COBRA Subsidies and the Remaining Action Item for Plan Sponsors

The American Rescue Plan Act of 2021 (“ARPA”) kept many practitioners busy this spring/summer, as may be evident by our discussions here, here, here, and here. Under one of ARPA’s most impactful provisions, employees who were involuntarily terminated or had their hours reduced (and who met certain other criteria) became eligible for fully subsidized COBRA...… Continue Reading
August 9, 2021

The IRS Adds Helpful New Features to Its Correction Program

Every few years, the IRS enhances its popular correction program for qualified retirement plans (the Employee Plans Compliance Resolution System, or EPCRS) to continue to encourage plan sponsors to correct any plan failures and bring their plans into compliance.  Revenue Procedure 2021-30 reflects this latest enhancement of IRS correction guidance.  Here is a summary of...… Continue Reading
July 25, 2021

IRS Issues Additional Guidance on the Tax Treatment of Dependent Care Benefits

As the IRS continues to churn out guidance on various forms of COVID-19 relief, this week is no exception with the release of Notice 2021-26.  This Notice clarifies two key points relating to the tax treatment of dependent care assistance program (DCAP) benefits for 2021 and 2022. We previously wrote about the optional increased annual...… Continue Reading
May 13, 2021

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 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 changes are...… Continue Reading
March 11, 2021

Mid-Year Safe Harbor Design Changes in a COVID-19 World

As COVID-19 continues its upheaval of nearly all aspects of life, retirement plan administration included (see some of our prior discussions here, here, here and here), the Internal Revenue Service recently issued guidance providing additional relief for the sponsors of certain plans.  IRS Notice 2020-52 clarifies requirements for mid-year changes to a safe harbor 401(k)... Continue Reading…
July 7, 2020

Mid-Year Safe Harbor Design Changes in a COVID-19 World

As COVID-19 continues its upheaval of nearly all aspects of life, retirement plan administration included (see some of our prior discussions here, here, here and here), the Internal Revenue Service recently issued guidance providing additional relief for the sponsors of certain plans.  IRS Notice 2020-52 clarifies requirements for mid-year changes to a safe harbor 401(k)...… Continue Reading
July 7, 2020

Expanding the Safe Harbor for (Certain) Electronic Disclosures

We previously wrote about the Department of Labor’s proposed expansion of its safe harbor for electronic delivery of certain retirement plan disclosures required under ERISA.  The wait is finally over, with publication of the final rule (the “New Rule”) helped along by the DOL’s desire to alleviate some of the “disclosure-related problems being reported by... Continue Reading…
June 3, 2020

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