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Kellie M. ThomasBlog Posts

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  • Group Health Plan Considerations in the Face of (Potentially) Changing Abortion Laws

    On May 2, 2022, a draft opinion from the U.S. Supreme Court case Dobbs v. Jackson Women’s Health was leaked to the press, and as a result the Court is expected to overturn Roe v. Wade and Planned Parenthood v. Casey, effectively leaving the issue of abortion rights to the states. Thirteen states currently have laws in place...
    June 14, 2022
  • Crypto, SDBAs, and Your 401(k) Plan: What Now?

    Just over a month ago, we wrote about the Department of Labor’s guidance on cryptocurrency as a 401(k) investment option, and the landscape has already shifted multiple times. Fidelity Investments made news on April 26 when it announced its new cryptocurrency-based investment option for 401(k) plans and other investment vehicles.  If elected by a plan...
    May 17, 2022
  • Is Crypto Too Cryptic for Your 401(k) Plan?

    It started sometime last year and, in hindsight, was inevitable.  Clients with 401(k) plans and a crypto-savvy employee population began asking whether they could offer cryptocurrency as a plan investment option.  In the 401(k) world, where even a self-directed brokerage window with built-in investment limitations can be too risky, the answer seemed obvious – watch...
    March 21, 2022
  • 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

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