Seyfarth Synopsis: The IRS has released final instructions for completing Forms 1094-C and 1095-C for 2021. Notably the instructions provide that the due date for furnishing Form 1095-C to individuals is extended to March 2, 2022. As expected, the instructions no longer offer penalty relief for good faith incorrect or incomplete filings and Form
Employee Health & Welfare Benefit Plan Limits
The Internal Revenue Service (IRS) recently released 2022 cost-of-living adjustments applicable to dollar limitations for employer-sponsored health and welfare plans and retirement plans.
The changes in the 2022 cost-of-living adjustments for employer-sponsored health and welfare plans are summarized in the table below:
| Health and Welfare Plan Limits (Rev. Proc. 2021-45 and Rev. Proc. |
Waistbands Aren’t the Only Thing Requiring Flexibility During the Pandemic
The Consolidated Appropriations Act of 2021 (“CAA”) offers significant relief for employers sponsoring flexible spending accounts. After much clamoring from the employer community, the IRS finally issued clarifying guidance in the form of Notice 2021-15 (the “Notice”). Check out our full Legal Update for details.
The Biden Administration Removes Limits on Agency “Guidance” – And Creates A New Agenda Enforcement Tool
Synopsis: On January 20, 2021, the Biden Administration revoked the Trump Administration Executive Order (EO) which had restricted agency Guidance. On January 27, 2021, the Department of Labor (DOL) rescinded the “PRO Good Guidance” rule that it had issued pursuant to the Trump EO – a rule that limited the force of informal guidance in
Fate of EEOC Wellness Regulations Remains Unknown
Seyfarth Synopsis: Unpublished U.S. Equal Employment Opportunity Commission (EEOC) proposed regulations regarding incentives offered under wellness programs are set to be withdrawn and reviewed after the Biden White House issues a regulatory freeze.
On January 7, 2021, the EEOC forwarded to the Office of Federal Register its proposed rules under the Americans with Disabilities Act
Malfunctioning Transit Passes – Timing is Everything
Seyfarth Synopsis: Many employers maintain a tax-preferred transportation fringe benefit plan to provide tax-free transit benefits to employees. Under such plans, the benefit is often distributed in the form of an electronic voucher or payment card. However, if the electronic payment card malfunctions after it is received, cash reimbursements for transit expenses will be
Thought You Paid Your Last PCORI Fee? Wrong!
Seyfarth Synopsis: We previously blogged that the so-called Cadillac tax was movin’ out. Well, the Patient-Centered Outcomes Research Institute (“PCORI”) fee is moving back in. On December 20th, the President signed the “Further Consolidated Appropriations Act, 2020” (the “Act”), which repealed the Cadillac tax as well as the annual fee on health insurance providers. The
Cadillac Tax is Movin’ Out
Seyfarth Synopsis: Although it is not law yet, according to the must-pass spending legislation passed by both the House and Senate, it looks like the infamous Cadillac Tax and the Annual Fee on Health Insurance Providers (HIP Fee) will both be repealed for good. Absent any unforeseen circumstances, the President is expected to sign it