Welcome to the December 2024 edition of Benefits Buzz ! In this issue, we dive into the latest topics related to employee benefits, wellness programs and ever-evolving workplace dynamics. Stay informed and gain insights that help you make the most of your benefits package.  This month's highlights  Topic #1: A brief breakdown of IRS employee benefit plan limits for 2025.  Topic #2: Federal agencies seek to expand coverage for OTC contraceptives under Notice 2024-75, which could impact high-deductible health plans and issuers.   [Download the Full Story PDF]   Stay informed, stay empowered and make the most of your benefits with Benefits Buzz! Be sure to follow us on LinkedIn for monthly updates and never miss out on the latest in benefits news.  Questions?  If you have questions, contact TruePlan . Our team of advisors can help you with questions within the scope of employee benefits .    Read our last Benefits Buzz on ACA reportin...

The economic and societal lockdowns that have been imposed in an attempt to slow the spread of the coronavirus have presented unique challenges, including some that may not have been contemplated when the lockdowns were instituted. Congress was quick to pass the CARES Act , which gave retirement plan participants greater access to their plan balances through expanded loan and hardship distribution provisions. However, a stumbling block quickly became apparent when plan provisions required spousal consent for some distributions or loans. Spousal consent waivers for plans subject to qualified joint and survivor annuity provisions of Section 417 of the Internal Revenue Code generally must be witnessed in the physical presence of a plan representative or a notary public. Similarly, the same spousal consent and witnessing requirements apply to designate a non-spouse beneficiary for a 401(k) or ERISA-covered 403(b) plan. Physical presence can be difficult to achieve in light of stay-at-home...

As described in our previous article on participant notices, plan sponsors of qualified retirement plans must routinely provide various notices to participants and beneficiaries regarding plan provisions, investment information, fees and more.  On May 21, the U.S. Department of Labor released new regulations regarding the electronic disclosure of these notices, ushering in an era of convenience for a historically arduous requirement. Electronic delivery rules have existed for years, but abiding by them has been prohibitive, particularly when delivering to employees not using a computer as an integral part of work duties. The new rules do not replace the existing ones, but instead offer a more feasible alternative to them. In short, the new safe harbor framework allows sponsors to provide required notices directly via email or to make them available on the internet under certain requisite conditions. The process can be applied for participants who have provided an email address or ...

As described in our previous article on participant notices, plan sponsors of qualified retirement plans must routinely provide various notices to participants and beneficiaries regarding plan provisions, investment information, fees and more.  On May 21, the U.S. Department of Labor released new regulations regarding the electronic disclosure of these notices, ushering in an era of convenience for a historically arduous requirement. Electronic delivery rules have existed for years, but abiding by them has been prohibitive, particularly when delivering to employees not using a computer as an integral part of work duties. The new rules do not replace the existing ones, but instead offer a more feasible alternative to them. In short, the new safe harbor framework allows sponsors to provide required notices directly via email or to make them available on the internet under certain requisite conditions. The process can be applied for participants who have provided an email address or ...

The Internal Revenue Service (IRS) has recently released the contribution limits on Qualified Retirement Plans for 2016. HANYS Benefit Services created a chart that details the  2016 contribution limits . Should you have questions, please contact HANYS Benefit Services by calling (800) 388-1963 or email us at hbs@hanys.org.

The new ACA Information Center for Applicable Large Employers page on IRS.gov features information and resources for employers of all sizes on how the health care law may affect them if they fit the definition of an applicable large employer. The web page includes the following sections: What’s Trending for ALEs,  How to Determine if You are an ALE,  Resources for Applicable Large Employers, and  Outreach Materials.  Visitors to the new page will find links to: Detailed information about tax provisions including information reporting requirements for employers,  Questions and answers, and  Forms, instructions, publications, health care tax tips, flyers and videos.  Although the vast majority of employers will not be affected, you should determine if you are an applicable large employer. If you averaged at least 50 full-time employees, including full-time equivalent employees, during 2014, you are most likely an ALE for 2015. If you have fewer than ...

The Internal Revenue Service (IRS) recently announced modified correction methods for errors relating to automatic contribution features, including automatic enrollment, automatic escalation, and employee elective deferrals in both 401(k) and 403(b) plans. The correction methods in the new Revenue Procedure 2015-28 are in addition to those previously identified in Revenue Procedure 2013-12. These new correction methods will encourage employers to more readily include automatic enrollment features in their defined contribution plans. BACKGROUND: ELECTIVE DEFERRAL FAILURES Defined contribution plans with automatic enrollment or automatic escalation must take deductions from employees as soon as possible after enrollment. An “elective deferral failure” occurs if an employer fails to implement deductions properly or in a timely manner because: the eligible employee was not automatically enrolled; the employee’s deferral election was not properly implemented; the deferral percentage was ...

The Internal Revenue Service (IRS) has recently released the contribution limits on Qualified Retirement Plans for 2015. HANYS Benefit Services created the  attached chart  that details these contribution limit increases. If you have any questions about the COLA Limits, or would like to speak with an advisor about reviewing or establishing a plan, please contact us at (800) 388-1963 or via e-mail at hbs@hanys.org.

On April 4, 2014, the IRS issued  Notice 2014-19  which provides additional guidance on how qualified retirement plans should treat the marriages of same-sex couples following the June 26, 2013 Supreme Court’s ruling in United States v. Windsor. The Windsor decision invalidated Section 3 of the 1996 Defense of Marriage Act (DOMA) that barred same-sex couples from being treated as married under federal law. Subsequent to the Windsor decision, the IRS issued  Revenue Ruling 2013-17  which stated that a couple would be considered married for federal tax purposes if their marriage certificate was issued by a jurisdiction having the legal authority to sanction marriages. Moreover, once married, the IRS would consider the couple to be married, even if domiciled in a state that does not recognize same-sex marriages. Notice 2014-19 provides guidance on how to comply with the provisions of the Revenue Ruling. Specifically, the Notice provides guidance on the following: Plan o...

The Internal Revenue Service (IRS) has recently released the contribution limits on Qualified Retirement Plans for 2014. HANYS Benefit Services created the  attached chart   that details these contribution limit increases. If you have any questions about the COLA Limits, or would like to speak with an advisor about reviewing or establishing a plan, please contact us at (800) 388-1963 or via e-mail at  hbs@hanys.org .

Earlier this year, the Internal Revenue Service (IRS) announced that its Employee Plans Compliance Unit (EPCU) would begin a compliance check of certain 457(b) plans maintained by non-governmental, tax-exempt entities. These plans, commonly referred to as “Top Hat” plans, are frequently offered by tax-exempt organizations in addition to other qualified retirement plans. The good news is that the extent of the compliance check is fairly limited. Letters and a questionnaire will be sent to 200 tax-exempt organizations in fiscal year 2013, and another 200 will be sent in fiscal year 2014. Employers will be selected for review based on information contained on 2011 Form W-2 and Form 990. If you receive a compliance check letter from the IRS, it is important that you respond in a timely fashion (15 days from the date of the letter) and provide the requested information. Although responding to the questionnaire is voluntary, failure to do so may result in the IRS initiating an audit of...

Earlier this year, the Internal Revenue Service (IRS) announced that its Employee Plans Compliance Unit (EPCU) would begin a compliance check of certain 457(b) plans maintained by non-governmental, tax-exempt entities. These plans, commonly referred to as “Top Hat” plans, are frequently offered by tax-exempt organizations in addition to other qualified retirement plans. The good news is that the extent of the compliance check is fairly limited. Letters and a questionnaire will be sent to 200 tax-exempt organizations in fiscal year 2013, and another 200 will be sent in fiscal year 2014. Employers will be selected for review based on information contained on 2011 Form W-2 and Form 990. If you receive a compliance check letter from the IRS, it is important that you respond in a timely fashion (15 days from the date of the letter) and provide the requested information. Although responding to the questionnaire is voluntary, failure to do so may result in the IRS initiating an audit of...

The Plan Sponsor Council of America (PSCA) recently released the 2013 403(b) Plan Survey. The survey showed that 73.6% of plans offer target date funds (TDF) as an investment option. Similar findings were noted for 401(k) plans. Additionally, many plan sponsors have identified TDFs as their plan’s qualified default investment alternative (QDIA). Target date funds can be an attractive investment option for employees who do not want to actively manage their retirement portfolio. The inflow of monies into TDFs in recent years reflects the growing popularity of these types of investments. Employers and plan fiduciaries have an obligation to prudently select and monitor the investments  offered in their retirement plan . Although all TDFs have similar characteristics, regardless of the investment provider, there are several differences that can significantly affect the way a TDF performs. It is important that fiduciaries understand these differences when deciding which TDF is appropriat...

Beginning in 2014, the Affordable Care Act (ACA) requires health plans offered through an Exchange, or qualified health plans (QHPs), to meet certain levels of actuarial value. ACA’s required actuarial value levels are referred to as “ metal levels ”—bronze, silver, gold and platinum. ACA’s metal levels are intended to allow consumers to compare plans with similar levels of coverage in order to help them make informed decisions about their health insurance coverage. Since coverage will be similar for all plans in a metal tier (for example, all silver plans), consumers can focus on other plan factors, such as the premium and network of providers, when selecting a health plan. QHP issuers must offer at least one plan in the silver level and one plan in the gold level through the Exchanges. Outside of the Exchanges, non-grandfathered plans in the individual and small group markets must offer coverage that matches up to the metal levels. Actuarial Value Actuarial value is calculated as the...

The Obama Administration has postponed the Affordable Care Act (ACA) employer mandate penalties for one year, until 2015. The Department of the Treasury announced the delay on July 2, 2013, along with a similar delay for information reporting by employers, health insurance issuers and self-funded plan sponsors. The delay does not affect any other provision of the ACA, including individuals’ access to premium tax credits for coverage through an Exchange. The Treasury plans to issue more formal information about the delay within a week. ONE-YEAR IMPLEMENTATION DELAY The employer mandate provisions of the ACA are also known as the employer shared responsibility or pay or play rules. These rules impose penalties on large employers that do not offer affordable, minimum value coverage to their full-time employees and dependents. They were set to take effect on Jan. 1, 2014. According to the Treasury, the delay of the employer mandate was required because of issues related to the reporting re...