True to form, the IRS released long-awaited proposed regulations during a long holiday weekend. This time they are narrowly focused on the eligibility rules for Long-Term Part-Time employees first introduced under the SECURE Act, and then expanded by SECURE 2.0. But, they did not disappoint, and are chock full of useful and detailed information on
Seyfarth Synopsis: The IRS just announced the 2024 annual limits that will apply to tax-qualified retirement plans. For a third year in a row, the IRS increased the annual limits, allowing participants to save even more in 2024. Employers maintaining tax-qualified retirement plans will need to make sure their plans’ administrative procedures are adjusted accordingly.
In Notice 2023-75, the IRS announced the various limits that apply to tax-qualified retirement plans in 2024. The “regular” contribution limit for employees who participate in 401(k), 403(b) and most 457 plans will increase from $22,500 to $23,000 in 2024. The “catch-up” contribution limit for individuals who are or will be age 50 by the end of 2024 is not changing, and remains $7,500 for 2024. Thus, if you are or will be age 50 by the end of 2024, you may be eligible to contribute up to $30,500 to your 401(k) plan in 2024. These same limitations apply if you work for a governmental or tax-exempt employer and participate in a 403(b) plan.
Seyfarth Synopsis: In August, the Ninth Circuit Court of Appeals revived a challenge by Airlines for America (“A4A”), to San Francisco’s Healthy Airport Ordinance (the “Ordinance”), which requires airlines that use the San Francisco International Airport, which the City runs, to provide enhanced health plan benefits to the airlines’ employees and their dependents. A4A, an
Seyfarth Synopsis: The IRS has announced adjustments decreasing the affordability threshold for plan years beginning in 2024, which may cause employers to have to pay more for ACA compliant coverage in 2024.
The IRS recently released adjustments decreasing the affordability threshold for plan years beginning in 2024 in Revenue Procedure 2023-29.
Under the Affordable
This post was originally published to Seyfarth’s Global Privacy Watch Blog.
As organizations begin renewing and entering into new contractual relationships for 2024, an oft-forgotten aspect of the contracting process is determining whether a Business Associate Agreement (a “BAA”) is required. Under HIPAA, health care providers, health plans and health care clearinghouses (“Covered Entities”)
This afternoon, the IRS issued Notice 2023-62, providing welcome guidance relating to the mandatory Roth catch-up provision under Section 603 of the SECURE Act 2.0 (“S2”), which is effective for plan years beginning after December 31, 2023. First, the Notice clarifies that catch-up contributions are still allowed after 2023, despite a technical glitch in S2. Second
Enacted in December 2022, the SECURE 2.0 Act contains over 90 provisions that impact qualified retirement plans. Notably, SECURE 2.0 mandates the adoption of auto-enrollment features for plans established after its enactment. Grab your cup of coffee and tune in to hear Richard and Sarah chat with Matthew Calloway from Mercer, about the effects that
Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance throwing more cold water on the tax treatment of these types of products, that the Administration has dubbed “junk insurance”.
On July 7th, the Treasury Department, Department of Labor, and Health and Human Services (the “agencies”) issued proposed rules impacting “junk insurance”. The guidance proposes (i) changes to what qualifies as short-term, limited-duration insurance, (ii) amendments to the requirements for independent, non-coordinated coverage, and fixed indemnity insurance to be considered an “excepted benefit”, and (iii) clarifications of the tax treatment of fixed amount benefit payments under employment-based accident and health plans. The IRS also asks for comments on coverage limited to specified diseases or illnesses that qualifies as excepted benefits and on level-funded plan arrangements.
Continue Reading My Insurance Doesn’t Cover That? Agency Guidance on “Junk Insurance”
Seyfarth Synopsis: Employer health plan sponsors, administrators, and insurers have been eagerly awaiting the U.S. Department of Labor’s upcoming guidance on mental health parity. According to recent reports, newly proposed MHPAEA regulations have been sent to the White House for review and their public release is imminent.
In 2020, Congress amended the Paul Wellstone and
Seyfarth Synopsis: In light of the end of the COVID-19 National Emergency and Public Health Emergency (see our prior blog post here), the Internal Revenue Service (“IRS”) has announced the end of prior COVID-19-related special rules for health plan coverage.
On June 23, 2023, the IRS issued Notice 2023-37 to clarify the compatibility of