Posts Categorized: Welfare Benefits

KT Submits Comments Concerning the PCOR Fee

in Welfare Benefits

Today, the health and welfare team submitted comments to the IRS regarding the PCOR Trust Fee proposed regulations. These comments request that the IRS exempt stand-alone HRAs from the PCOR fee, if the HRA funds are being used to purchase otherwise exempt benefits. The comments can be viewed here: Comments with IRS to Exempt Stand-Alone HRAs from the PCOR Trust Fee

Teleconference – Planning for 2013

in Court Cases, Health Benefits, Welfare Benefits

Please note our health and welfare compliance session for 2013. We will be discussing the Supreme Court case and other issues relevant to planning for the 2013 plan year. You can sign up on the KT website under the Knowledge Center and Events, or by using the following specific web address. 2013 Health and Welfare Planning : ACA Implementation Continues

DOL Regulatory Update

in Health Benefits, Welfare Benefits

DOL recently released its 2012 regulatory agenda, with a few interesting items emerging.  The agenda indicates that DOL will propose updates to the internal claim and appeal procedures for plans not covered by the Affordable Care Act (e.g., stand-alone dental and vision, disability and retirement plans).  These regulations were last updated in 2001.  I first heard of these proposed updates during the JCEB health and welfare meeting that I co-chaired a few months ago.  At that time, DOL indicated that it was examining whether any of the enhancements that apply to the internal claims and appeals procedures under the Affordable Care Act,… Continue Reading

DOL Solicits Comments for Document Requests

in Health Benefits, Welfare Benefits

ERISA Section 104(a)(6) requires entities to provide documents to the Secretary of Labor upon request.  DOL has issued an information collection request soliciting public comments as to what types of documents this request should cover and whether it should be continued.  Interested parties must submit comments by January 12, 2012.

DOL Audits

in Health Benefits, Welfare Benefits

The Department of Labor’s initiative to review the quality of employee benefit plan financial audits has been in place for many years, but there are signs that it has recently intensified. We have heard that the DOL is starting to dig deeper into the financial audits that are filed with the Form 5500 and in some cases have rejected the audits and imposed penalties. Because the audit report is considered an integral part of a Form 5500 filing for funded plans with at least 100 participants, plan administrators are at risk if the DOL determines that audit procedures were inadequate. The… Continue Reading