IRS Releases 401(k) Guidance For Long-Term Part-Time Employees Under the Secure 2.0 Act
On November 24, 2023, the IRS released long-awaited guidance around the updated 401(k) eligibility requirements pertaining to long-term part-time employees (LTPT) under the SECURE 2.0 Act of 2022 (SECURE 2.0). These proposed regulations, if finalized, would amend the rules previously applicable to 401(k) plans and provide additional clarification for some of the questions plan sponsors […]
IRS Issues 2024 FSA and Commuter Limits
On November 9, 2023, the IRS released the long awaited 2024 maximum contribution limits for Flexible Spending Arrangements (FSA) and Commuter accounts. A bit later than usual, Revenue Procedure 2023-34 follows the IRS’s announcement of the 2024 401(k) annual contribution limits, which were released November 1st. For taxable years beginning in 2024, the annual contribution […]
Departments Move Forward with Enforcement of Deferred Machine-Readable File Requirement
The Departments of Labor, Health and Human Services and Treasury (The Departments) have released updated FAQs around the requirement for plans and issuers to post machine-readable files on a public website. Per the Consolidated Appropriations Act, 2021 (CAA), plans and issuers were required to post, in three separate machine-readable files, information related to the in-network […]
Joint Agency Guidance on Gag Clause Prohibition for Health Plan Agreement
On February 23, 2023, the Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Internal Revenue Service (IRS) (the “Agencies”) released FAQs addressing the implementation of certain transparency requirements under the Consolidated Appropriations Act of 2021 (CAA). These joint-issued FAQs address additional compliance guidance on the CAA’s annual attestation, prohibiting […]
IRS Delays Roth Catch-Up Contribution Requirement under SECURE 2.0 Act
In light of concerns expressed by plan sponsors and participants alike, the IRS released Notice 2023-62 (“Notice”) which provides a two-year extension on the requirement related to Roth catch-up contributions under SECURE 2.0 Act (“the Act”). Specifically, the Notice states, “The Department of Treasury and the IRS have been made aware of taxpayer concerns with […]
EEOC Announces 2022 EEO-1 Component 1 Submission Deadline
The U.S. Equal Employment Opportunity Commission (EEOC) has announced that the 2022 EEO-1 Component 1 data collection deadline for employers to submit demographic data. For 2022, data collection will begin on October 31, 2023. Eligible employers have until December 5, 2023, to submit their EEO-1 reports. The EEO-1 Component 1 report is a mandatory annual […]
IRS Releases ACA Affordability Threshold for 2024
The IRS released Rev. Proc. 2023-29 on August 23, 2023, announcing a decrease in the ACA Affordability Contribution Rate from 9.12% in 2022 to 8.39% for the 2024 plan year. This is an even greater decrease from what was announced for the 2023 tax year, which was formerly the most significant decrease since the ACA’s […]
Notice of Proposed Rulemaking Released for the Pregnant Workers Fairness Act
The U.S. Equal Employment Opportunity Commission (EEOC) has issued a Notice of Proposed Rulemaking around the implementation of the Pregnant Workers Fairness Act (PWFA). The proposed rule, released for inspection August 7, 2023, aims to provide some needed clarification for employees and employers as they navigate the requirements under PWFA. As background, PWFA requires covered […]
New FAQ On No Surprise Act
Recently, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) released new frequently asked questions (FAQs) on the No Surprises Act and the Transparency in Coverage final rules, giving employers more guidance and clarity around health plan out-of-network providers and fee disclosures. Under the Affordable Care Act (ACA), out-of-pocket expenses related to […]
DHS Terminates I-9 Form Remote Option Flexibility; Considerations for Remote Workers
For employers that remotely verified I-9 forms during the pandemic, the deadline for completing in-person verification is fast approaching. As background, the Department of Homeland Security (DHS) had provided additional flexibility due to COVID-19 to review I-9 documentation remotely and had previously announced that employers would have until July 31, 2023, to complete an in-person […]
