EBIA Weekly Newsletter

What Are the Rules for Requesting an IRS Determination Letter on Plan Termination?

   December 14, 2017

QUESTION: We are terminating our 401(k) plan effective December 31, 2017, and want to request an IRS determination letter on the plan’s qualification at the time of termination. Could you review the rules for requesting a plan termination determination letter? ANSWER: While requesting a determination letter on the plan’s qualification at the time of termination … Read More

CMS Memorandum Addresses Notice Requirements Relating to Exemptions From Contraceptive Coverage Mandate

   December 7, 2017

CMS Memorandum: Notice by Issuer or Third Party Administrator for Employer/Plan Sponsor of Revocation of the Accommodation for Certain Preventive Services (Nov. 30, 2017) Available at https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/Notice-Issuer-Third-Party-Employer-Preventive.pdf CMS has issued a memorandum addressing the notice requirements applicable to non-grandfathered health plans sponsored by entities with religious or moral objections to providing … Read More

IRS Identifies No Qualification Changes Affecting 401(k) Plans on 2017 Required Amendments List

   December 7, 2017

IRS Notice 2017-72 (Dec. 5, 2017) Available at https://www.irs.gov/pub/irs-drop/n-17-72.pdf The IRS has issued its 2017 Required Amendments List (RA List) for qualified retirement plans. Annual RA Lists identify changes in the qualification requirements that may result in disqualifying provisions and require a remedial amendment. (A “disqualifying provision” is a required provision … Read More