The US Departments of Labor, Health and Human Services, and the Treasury (Departments) issued a set of 14 frequently asked questions (FAQs) on April 11. The FAQs are intended to offer guidance on the application and implementation of the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and other health coverage issues related to the coronavirus (COVID-19).
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EXAMINING A RANGE OF EMPLOYEE BENEFITS
AND EXECUTIVE COMPENSATION ISSUES
AND EXECUTIVE COMPENSATION ISSUES
The $100,000 limit on coronavirus related distributions (CVRD) under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) is both an individual limit and a plan limit. Tracking and enforcing the $100,000 limit has the potential to create special compliance issues for employers and controlled group affiliates that sponsor more than one retirement plan and have individuals with an account balance under more than one of those plans.
Due to the economic and financial upheaval caused by the coronavirus (COVID-19) pandemic, many employees are asking their employers if they are able to cancel their deferral elections and/or receive accelerated payments from their nonqualified deferred compensation plan accounts to help offset financial difficulties they may be facing.
The Coronavirus Air, Relief, and Economic Security (CARES) Act signed into law on March 27 includes an allocation of $200 million to the Federal Communications Commission (FCC) to support telehealth services and $125 million to the US Department of Agriculture’s Rural Utilities Service to expand its existing distance learning, telehealth, and broadband initiative.
The IRS has extended the last day of the Initial Remedial Amendment Period for Section 403(b) plans from March 31, 2020 to June 30, 2020.
As the effects of the coronavirus (COVID-19) pandemic hit the United States, downsizings and shutdowns are spreading indiscriminately throughout the economy.
During the economic upheaval caused by coronavirus (COVID-19), defined contribution plan participants (i.e., participants in 401(k) plans, 403(b) plans, etc.) may look to their plan account balances to alleviate financial challenges.
Single employer defined benefit plans are required to comply with limitations on accelerated benefits payments, future benefit accruals, and implementation of benefit increases triggered by plan underfunding or plan sponsor bankruptcy.
Employers with self-insured health plans may be thinking about making coronavirus (COVID 19)-related changes, such as waiving the patient responsibility portion of the charge for a hospital stay that is related to COVID-19. If there is stop loss insurance, it is important to consider the implications of a plan design change.
Our employee benefits and executive compensation practice is available to help employers evaluate and troubleshoot potential issues arising from the changing work environment and economic situation caused by the COVID-19 pandemic.