Thursday, February 16, 2012

IRS chart for W-2 reporting of health care costs

The IRS website contains a chart which is a handy reference regarding what is and what isn't includible in calculating reportable health care costs on W-2s.

Thursday, February 9, 2012

DOL issues Technical Release 2012-01 with Health Care Reform FAQ

The DOL issued Technical Release 2012-01 containing 7 FAQs regarding various topics including automatic enrollment (not effective until 2014); intent to issue guidance regarding the coordination of the 90 day waiting period rules of the IRC and the PHS; anticipated "look back" period for determining whether an employee is a full time employee and a discussion regarding whether a newly hired employee is a full time employee.

DOL issues final regulations on the Summary of Benefits and Coverage

The DOL issued final regulations on the Summary of Benefits and Coverage today.

We will prepare an ErisaALERT on this and other recent guidance shortly.

Friday, February 3, 2012

EBSA Issues final 408(b)(2)regulations

EBSA issued final 408(b)(2) regulations and postponed the effective date until July 1, 2012 (see ErisaALERT 2010-11 for a discussion of the proposed rules). The final regulation is effective for both new and existing contracts or arrangements. 

As a result of the extension, the deadline for participant disclosures (see ErisaALERT 2010-12) is extended to August 30, 2012. In addition, the first quarterly participant statement which must reflect fees and expenses deducted from the participant's account is due November 14, 2012 for the quarter ending September 30, 2012.

The EBSA website provides a list of the major changes.