Employee Benefits Law Report

Tag Archives: Internal Revenue Service

IRS issues proposed Code Section 409A regulations clarifying many nonqualified deferred compensation plan issues

By Greg Daugherty on
The Internal Revenue Service (IRS) recently published proposed regulations under Internal Revenue Code Section 409A. The proposed regulations clarify 19 policy items addressed in the final regulations published in 2007 and also in proposed income inclusion regulations published in 2008. These clarifications generally are not surprising, and we do not expect that employers will need … Continue Reading

After Earlier Grace, Departments Now Relax Certain Health Claims Procedure Requirements

By Jim Prior on
Fresh off an extension this past spring of an enforcement grace period with respect to internal health claims and appeals requirements, sponsors of non-grandfathered group health plans received some more welcome news recently with the relaxation of certain group health claims procedure requirements first announced in interim final rules issued in July 2010. Although plan … Continue Reading

Department of Labor Extends More Grace on Internal Health Claims and Appeals

By Jim Prior on
In Technical Release 2011-01, the Department of Labor has extended the enforcement grace period with respect to certain internal claims and appeals requirements applicable to non-grandfathered health plans under the Patient Protection and Affordable Care Act (PPACA) and its implementing regulations. The internal health claims and appeals requirements generally apply to non-grandfathered plans as of … Continue Reading
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