Employees and employers, now more than ever, need to take the appropriate steps to ensure that prudent decisions are made in respect to employees saving at an adequate deferral rate, establishing an appropriate asset allocation mix, and planning to replace income throughout their retirement.Read White Paper
On February 10th the government issued final regulations regarding the “Employer Shared Responsibility” (ESR) requirements of the Affordable Care Act. This is often referred to as the law’s “Pay or Play” feature.Read More
There is a new mandatory electronic filing requirement (known as "EFAST2") that now applies to your Form 5500 filings.Read More
With the continued upward pressure on cost and pricing constraints imposed by Health Care Reform, insurers and health plans are exploring new ways to drive consumer and provider behavior.Read White Paper
Recent Industry News
At the Summit
Q4 2014 Market Update Available!
IRS Announces 2015 Pension Plan Limits
The Internal Revenue Service recently announced the cost of living adjustments affecting dollar limitations for pension plans and other retirement-related items for Tax Year 2015.
Q3 2014 Market Update Available!
Congress Provides Pension Funding Relief for Defined Benefit Plan Sponsors
Congress recently passed the Highway and Transportation Funding Act of 2014 (HTFA) and President Obama signed the bill into law on August 8th. This legislation includes an extension of MAP-21 pension interest rate smoothing as a revenue
Department of Labor Update
Proposed Regulation to Require a Guide to Assist Plan Fiduciaries in Reviewing 408(b)(2) Disclosures
U.S. Treasury and IRS Revenue Ruling 2013-17
Guidance on Application of Same-Sex Marriage
On August 29th, the U.S. Treasury and IRS issued Revenue Ruling 2013-17 to address marriage of same-sex individuals for federal law purpopses.
DOL Provides Relief for Second Round of 404(a)(5) Disclosures
On July 22, 2013, the Department of Labor (DOL) issued Field Assistance Bulletin (FAB) 2013-02, which announced a transitional enforcement policy regarding the due date for the second round of 404(a)(5) participant disclosure regulations.
HIPAA Certificate of Creditable Coverage Requirement Eliminated
Because "Pre-existing Condition" limits are no longer allowed under law, as of December 31, 2014, health plan sponsors are no longer required to provide a HIPAA "Certificate of Creditable Coverage" to individuals terminating from a plan.
Plan administrators should no longer provide the HIPAA certificate to employees whose termination date occurred after 12/30/2014.
Note that individuals losing coverage as the result of a COBRA qualifying event (at termination of employment, for example), or at the end of their COBRA period of coverage will be able to enroll in a "Marketplace" or "Exchange" plan (if eligible) without pre-existing condition restrictions.
End of Year Action Items 2014
As 2014 comes to a close, it's the time of year to review those end-of-the-year benefit plan "action items" that may require your attention:
W-2 Reporting requirement: Include the full cost of health insurance on employee W-2's that will be issued in 2015 for tax year 2014. Applies to: Employers who issued 250 or more W-2's for the tax year 2013.
This does not create taxable income - it is an informational item to be reported in Box 12 with the code "DD". Employers with insured plans will report the actual premium and those sponsoring self-insured plans will report the COBRA premium equivalent. The reportable cost is the total, including employer and employee contributions, and is based on the tier in which the employee participates (i.e., Single, Employee+1, Family, etc.). Mid-year changes (a change in coverage tier or renewal cost increase, for example) must be factored into the reportable amount. Reporting should be done without regard to whether such amounts are pre-tax, post-tax or imputed as income to the employee. Employers may choose to report premium for COBRA participants or may elect not to, as long as the decision is consistent. Action: make sure all systems are set to report this information on W-2's.
Patient-Centered Outcomes Research Institute (PCORI) Fee Due by July 31, 2014
Executive Summary: The PCORI fee is a part of the Affordable Care Act (ACA) designed to fund research into and publish information about evidence based medicine to help doctors and patients to make informed healthcare decisions. The PCORI fee applies to most health insurance policies (typically excluding Health Savings Accounts and Flexible Spending Accounts) with policy years ending after Sept 30, 2012. The fee, imposed on plan sponsors and insurance companies, starts at $1 per covered member in year 1, increases to $2 in year 2, and will be adjusted to reflect inflation in subsequent years.
Filing is due by July 31 of the year following the end of the plan year. Plans with plan years ending on October 1, 2012 through December 31, 2012 paid 1st year fees in July, 2013. Those plans will pay 2nd year fees this year. The balance of plans (those with plan years ending January 1, 2013 through September 30, 2013) will pay first year fees in 2014 (due by July 31), using IRS Form 720 (see instructions here: IRS Form 720)
90 Day Waiting Period Requirement and Employee Orientation Periods
Government Issues Final Regulations Regarding the “Pay or Play” Requirements of the Affordable Care Act
On February 10th the Internal Revenue Service and the Treasury Department issued “Final Regulations” governing the implementation of one of the next phases of the Affordable Care Act. This aspect of the law, called the “Employer Shared Responsibility” (ESR) is often referred to as the law’s “Pay or Play” feature because it includes potential penalties for certain employers that fail to offer coverage that provides “minimum value” and that is deemed “affordable” under the law.
This brief summary is intended to provide an overview of how the newly issued final regulations may apply to you.
End of the Year Action Items for Benefit Plans
As 2013 comes to a close, it's the time of year to review those end-of-the-year benefit plan "action items" that may require your attention.
MA Health Connector Eliminates Section 125 Plan and HIRD Requirements
Massachusetts Health Connector Eliminates Section 125 Plan and HIRD Requirements
On October 28th the Massachusetts Health Connector initiated significant changes to four key components of the Massachusetts Health Reform law. The changes, announced in Bulletin 03-13, took steps to eliminate a conflict between Massachusetts law and some provisions of the Affordable Care Act (ACA) and are designed to further align Massachusetts law with the ACA. Although the Bulletin announces the filing of legislation to enact the changes into law, it also says that the provisions should be considered effective immediately.
The announced changes will repeal the following Massachusetts health reform provisions:
-Section 125 plan requirement
-The recently created Section 125 Notification requirement
-Employer Health Insurance Responsibility Disclosure (Employer HIRD) report
-Free Rider Surcharge (which provided for potential penalties for employers who failed to offer a Section 125 plan)
Summit Financial Strategies Market Insight
Over the past few days, the market has taken investors on a roller-coaster ride, and I suspect many of us are feeling a bit queasy. No one likes to be jerked down and up and back down again. What’s going on?
New White Paper Available!
Net Investment Tax in 2013
Starting in 2013 high income taxpayers [whose income is at or above $200,000] may be subject to two new Medicare taxes which consist of a 0.9% tax on earned income and self-employment income, and a 3.8% tax on net investment income.
Tips for Managing Your Finances After a Divorce
Summit Financial Strategies Financial Planning Insight
Clarifying the Home Office Deduction for both Employees and Business Owners
Summit Financial Strategies Tax Insight
Summit Financial Strategies Financial Planning Insight
Today’s economic landscape is forcing us to reconsider what we thought we knew about diversification.
Securities and advisory services offered through Commonwealth Financial Network, Member www.finra.org and www.sipc.org, a Registered Investment Adviser. Fixed insurance products and services, as well as benefits consulting and plan administration, offered by Summit Financial Corporation are separate and unrelated to Commonwealth. Fixed insurance products and services, as well as tax services, offered by Summit Financial Strategies, Inc. are separate and unrelated to Commonwealth. This communication is strictly intended for individuals residing in the states of AL, AZ, CA, CO, CT, DC, DE, FL, GA, IL, ME, MD, MA, MI, NV, NH, NJ, NY, OH, OR, PA, RI, SC, TN, TX, VT, VA. No offers may be made or accepted from any resident outside these states due to various state regulations and registration requirements regarding investment products and services.