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A Message From Cheiron

03/19/20

An open letter to our clients

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IRS Makes Significant Enhancements to the EPCRS Program For Pension Plan Overpayments

07/22/21

The IRS has updated its procedures for correcting plan errors. The update provides new correction methods with respect to past overpayment of pension benefits.

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PBGC Issues Regulations on Special Assistance for Troubled Multiemployer Plans

07/13/21

The Pension Benefit Guaranty Corporation (PBGC) has issued interim final regulations under the American Rescue Plan Act of 2021 with respect to the special financial assistance for troubled multiemployer pension plans.

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Agencies Request Information Regarding Reporting on Medical and Pharmacy Costs

06/30/21

The Departments of Labor, Treasury, and Health and Human Services have published a request for information on the new reporting requirement for group health plans and health insurance issuers on prescription drug and medical services costs.

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IRS Further Extends Temporary Relief from Physical Presence Requirement and Requests Comments

06/28/21

The IRS has extended the relief from the requirement that participants and beneficiaries be physically present to have certain elections witnessed and notarized.

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HHS Sets 2022 Maximum Out-of-Pocket Limits; IRS Releases HSA Parameters for 2022

05/17/21

The Department of Health and Human Services (HHS) and the Internal Revenue Service (IRS) have announced the maximum out-of-pocket limits for health plans and health savings accounts for 2022, as well as certain other changes.

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Not all Public Sector Hybrid Retirement Plans are Created Equal

05/12/21

Cheiron's Elizabeth Wiley co-authored a report with Dan Doonan, the executive director of the National Institute of Retirement Security, on public sector hybrid retirement plans.

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Agencies Issue Additional Guidance on the 100% COBRA Subsidy

04/16/21

The American Rescue Plan Act of 2021 provides for 100% premium assistance for COBRA continuation coverage for eligible individuals.

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Single-Employer Pension Plan Funding Requirements Reduced

03/17/21

The American Rescue Plan Act of 2021 made permanent changes to the funding requirements for single-employer pension plans.

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Troubled Multiemployer Plans Get Relief

03/11/21

The American Rescue Plan Act of 2021 provides relief for troubled multiemployer plans.

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Group Health Plans Must Perform Comparative Analyses of Non-Quantitative Treatment Limitations under Mental Health Parity

03/03/21

The Consolidated Appropriations Act, 2021, adds new requirements for group health plans that provide mental health and substance use disorder benefits effective on February 10, 2021.

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Pension Relief Bill Clears Key House Committee

02/16/21

The House Ways and Means committee passed a pension relief bill to be included in the COVID-19 relief bill that will be considered.

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Budget Bill Special Rules for FSAs

01/27/21

Special Rules for Flexible Spending Arrangements (FSAs) Contained in the Consolidated Appropriations Act, 2021 (the Budget Bill).

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IRS Announces 12 Cent Increase in 2020-2021 PCORI Fee

01/25/21

The IRS has announced the latest PCORI fee increase.

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Relief for Furnishing 2020 Forms 1095-B and 1095-C to Individuals

01/05/21

The IRS has announced a short delay in the furnishing of ACA reporting forms to individuals.

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Reminder: New SBC Templates and Glossary Required for Plan Years After December 31, 2020

12/01/20

Reminder: New SBC templates and glossary required for plan years after December 31, 2020.

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IRS Announces 2021 Pension Limits

10/28/20

The IRS has released the pension limits for 2021.

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PBGC Announces 2021 Premium Rates

10/16/20

The Pension Benefit Guaranty Corporation (PBGC) has released the premium rates for 2021.

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IRS Issues Guidance on Pension Distributions at Age 59 1/2

09/25/20

The IRS has provided guidance on the provision of last year's budget bill that reduced the age for permitted in-service distributions to age 59 .

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IRS Issues Guidance on Funding Relief for Single-Employer Defined Benefit Plans Under the CARES Act

08/28/20

The IRS has released guidance under the funding relief provision of the CARES Act.

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DOL Proposes More Flexibility for Increases in Copayments, Deductibles, and Out-of-Pocket Limits for Grandfathered Group Health Plans

08/04/20

The Departments of Labor, Health and Human Services, and the Treasury have proposed certain changes to the regulations for grandfathered health plans.

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Reminder: PCORI Fee Due July 31

07/08/20

The annual PCORI fee is due by July 31. (Your insurer will pay this if you are fully insured.)

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IRS Issues Guidance for COVID-19 Distributions from Retirement Plans

07/06/20

The Internal Revenue Service (IRS) has issued more guidance on coronavirus-related distributions.

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IRS Provides Relief for Certain Cafeteria Plan Rules During 2020 and Indexes the $500 Carryover Amount for Flexible Spending Accounts

07/02/20

The IRS issued two notices that permit easing certain restrictions that apply to cafeteria plans, flexible spending accounts and high deductible health plans (HDHPs).

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HHS Releases Maximum Out-of-Pocket Limits for 2021 & Revises Guidance on Drug Coupons; Certain HSA Limits Increase for 2021

07/01/20

The Department of Health and Human Services (HHS) and the Internal Revenue Service (IRS) have announced the maximum out-of-pocket limits for health plans and health savings accounts for 2021, as well as certain other changes.

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DOL's Final Alternative Electronic Delivery Rules for Pension Plans Permit Direct Delivery via Email

06/18/20

The Department of Labor has finalized their proposed electronic disclosure regulation that allows posting of documents on a website. The final regulation also allows the email of documents as an alternative.

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IRS Provides Temporary Relief From Physical Presence Requirement For Participant Elections

06/08/20

The IRS has provided relief from the requirement that participants and beneficiaries be physically present to have certain elections witnessed and notarized.

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Preparing for the Impact of the Pandemic on Your Pension Plan

06/04/20

Learn how to prepare your public pension plan for the impact of the pandemic.

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Extension of Certain Timeframes for Group Health Plans, Pension Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak

05/07/20

The Department of Labor and Internal Revenue Service have extended the timeframes for participants and beneficiaries to take certain actions with respect to group health plans. The extensions will substantially impact plan operations.

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Retirement Plan Distributions Permitted by the CARES Act

04/20/20

The CARES Act made a few changes in the rules for distributions and plan loans from retirement plans.

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Healthcare Provisions in the CARES Act

04/17/20

The CARES Act made some changes that impacted group health plans.

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CARES Act Provides Funding Relief for Single-Employer Defined Benefit Pension Plans

04/08/20

The CARES Act contained funding relief for single-employer pension plans. This alert describes the relief provided.

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SPECIAL ADVISORY on The Families First Coronavirus Response Act

03/20/20

The Families First Coronavirus Response Act that was enacted on March 18.

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HHS Rescinds Requirement for Health Plans to Adopt Unique Health Plan Identifiers

01/30/20

The Department of Health and Human Services (HHS) has issued a final regulation rescinding the requirement to use a health plan identifier (HPID).

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Agencies Propose Price Transparency Requirements for Group Health Plans

01/23/20

Price transparency requirements have been proposed by the Department of Health and Human Services (HHS), the Department of Labor (DOL), and the Internal Revenue Service (IRS) applicable to group health plans.

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2020 Budget Bill Includes Repeal of the Cadillac Tax, Health Insurer Tax, and Extension of the PCORI Fee

01/20/20

The recent budget bill for 2020 repealed a number of health related excise taxes, but extended on expiring tax.

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Relief for Furnishing Forms 1095-B and 1095-C to Individuals

01/17/20

The IRS has announced a short delay in the furnishing of ACA reporting forms to individuals.

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2020 Budget Bill Includes Changes for Defined Benefit Pension Plans

01/06/20

The budget bill that was passed in December made a number of changes impacting defined benefit pension plans.

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New Multiemployer Pension Reform Proposal Released

11/22/19

The Chairmen of the Senate Finance committee and the Senate Health, Education, Labor and Pension (HELP) committee have released a new multiemployer pension plan reform proposal that would make significant changes to the rules in ERISA and the Internal Revenue Code.

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PBGC Proposes Changes to Schedule R Reporting for Multiemployer Plans

11/15/19

The PBGC has proposed a revision to the instructions for Schedule R of Form 5500 that would impact multiemployer plans.

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DOL Proposes Alternative Electronic Delivery Rules for Pension Plans

11/13/19

The Department of Labor (DOL) has proposed a new alternative rule for the electronic disclosure to participants of certain documents.

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IRS Announces 2020 Pension Limits

11/06/19

The IRS has released the pension limits for 2020.

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IRS Expands List of Preventive Care Services for HSA Participants

11/06/19

The IRS has expanded the list of preventive care for HSA participants to include certain care for chronic conditions.

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Departments Allow Broader Use of Health Reimbursement Arrangements to Pay Individual Health Insurance Premiums

09/19/19

The Departments of Health and Human Services, Labor, and the Treasury have issued new regulations affecting the use of health reimbursement accounts (HRAs) and similar account based plans.

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Maximum Out-of-Pocket (MOOP) and HSA Limits Increase for 2020

07/30/19

The Department of Health and Human Services has published the maximum out-of-pocket limit for 2020, and made a change in how pharmaceutical manufacturer coupons are reflected in the out-of-pocket limits. In addition, the IRS has announced the changes to the limits for health savings accounts (HSAs). This alert describes the new limits and changes.

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Reminder: PCORI Fee Due July 31

07/12/19

The annual PCORI fee is due by July 31. (Your insurer will pay this if you are fully insured.) This is the final fee for some plans.

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HHS Proposes Changes to Rebates for Part D Plans Under the Anti-Kickback Statute

03/19/19

The Department of Health and Human Services (HHS) published proposed regulations that would change the treatment of rebates involving prescription drugs to Medicare and Medicaid plans and have requested feedback on many aspects of the proposals.

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Request for Information Regarding Grandfathered Group Health Plans

03/08/19

The Department of Health and Human Services (HHS) has requested information on grandfathered health plans.

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PBGC Proposes Simplified Methods for Withdrawal Liability Calculations

03/04/19

The Pension Benefit Guaranty Corporation (PBGC) has proposed changes to the regulations on withdrawal liability.

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SOA's New Mortality Tables May Not Affect Large Public Retirement Systems

01/28/19

New mortality tables may have little impact on large public retirement systems.

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9th Circuit Ruling on Partial Withdrawal Liability Clarifies Law

12/19/18

The 9th Circuit Court of Appeals has issued an opinion on the interaction of the 20-year cap on withdrawal liability and the credit for a prior partial withdrawal.

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Final PCORI Fee Amount Announced - A Six Cent Increase

11/30/18

The IRS has announced the latest PCORI fee increase.

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IRS Announces 2019 Pension Limits

11/02/18

The IRS has released the pension limits for 2019.

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PBGC Announces 2019 Premium Rates

10/18/18

The Pension Benefit Guaranty Corporation (PBGC) has released the premium rates for 2018.

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VCP Submissions Must be Electronic Beginning April 1, 2019

10/10/18

The IRS had made a substantial modification to the procedures for submitting requests under the Voluntary Correction Program (VCP).

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PBGC Issues Final Rules on Facilitated Mergers of Multiemployer Plans

10/01/18

The Pension Benefit Guaranty Corporation (PBGC) has issued its revision to the regulations concerning mergers of multiemployer pension plans to reflect the changes made by the Multiemployer Pension Reform Act of 2014 (MPRA).

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Mature Pension Plans are Sensitive--Manage with Care: A Survey of Public Plan Maturity Measures

09/21/18

The new actuarial standard of practice on the assessment and disclosure of risk (ASOP 51) highlights the importance of plan maturity. Mature pension plans are very sensitive to risks and need to be managed more carefully than less mature plans. This advisory describes some key public pension plan maturity measures and explores the range of those measures based on data from the Public Plans Database.

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Proposed Actuarial Standard Would Require Disclosure of Market-Based Liability

07/24/18

The Actuarial Standards Board (ASB) has released an exposure draft of changes to existing standards on the valuation of pension liabilities.

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New Actuarial Standard Requires Risk Disclosures in Pension Reports

07/10/18

Pension actuaries to disclose risks associated with pension plans under a new standard of practice.

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2017 PCORI Fee Payment Due by July 31, 2018

07/05/18

The annual PCORI fee is due at the end of July.

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Joint Committee on Multiemployer Plans Seeks Input from Stakeholders

04/27/18

The Congressional Joint Select Committee on Multiemployer Plans is soliciting comments.

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Maximum Out-of-Pocket Limits Increase for 2019

04/20/18

The Department of Health and Human Services (HHS) has announced the maximum out-of-pocket limit for 2019 as part of their latest Benefit and Payment Parameters regulation.

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Reminder: Plan Sponsors Must Comply with New Disability Claims Procedures by April 2, 2018

03/15/18

The Department of Labor (DOL) has announced that new disability claims procedures will apply for claims filed after April 1, 2018.

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Budget Bill Established Joint Committee on Solvency of Multiemployer Plans

02/13/18

The recent budget bill contains provisions for a Joint Select Committee on Solvency of Multiemployer Pension Plans.

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Budget Bill Suspends/Delays Certain ACA Taxes

02/02/18

The short-term budget bill suspended certain taxes and further delayed the "Cadillac Tax" under the Affordable Care Act.

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Tax Bill Makes Few Changes to Employee Benefits

12/29/17

Congress has passed the tax bill and it has been signed by the President.

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Multiemployer Plan Pension Rescue Bill Proposed

11/17/17

Senator Sherrod Brown (Ohio) has introduced a bill to address the multiemployer plan funding issues without benefit cuts.

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2018 Increases for Health FSAs and Transportation Fringe Benefits

10/27/17

The IRS has updated the maximum flexible spending account (FSA) limit and the transportation fringe benefit amounts for 2018.

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IRS Announces 2018 Pension Limits

10/20/17

The IRS has released the pension limits for 2018.

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PBGC Announces 2018 Premium Rates

10/20/17

The Pension Benefit Guaranty Corporation (PBGC) has released the premium rates for 2018.

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IRS Work Plan Provides Focus for Examination of Multiemployer Plans

10/19/17

The IRS has announced areas of focus when examining multiemployer pension plans in the coming fiscal year.

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IRS Publishes New Mortality Tables - Benefits Affected

10/17/17

The IRS has released new mortality tables for funding and benefit determinations.

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2017 PCORI Fee Announced - 13 Cent Increase

10/12/17

The IRS has announced the latest PCORI fee increase.

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Modification to Procedures for Applications for Multiemployer Plan Benefit Suspensions

08/03/17

The IRS has revised the procedures for filing for a suspension of benefit payments under the Multiemployer Pension Reform Act of 2014 (MPRA).

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2016 PCORI Fee Payment Due by July 31, 2017

07/11/17

The annual PCORI fee is due at the end of July.

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Important Limits Increase for 2018 Health Plans

06/14/17

The Department of Health and Human Services and the Internal Revenue Service have released maximum out-of-pocket limits for 2018 for non-grandfathered health plans and health savings accounts (HSAs).

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Qualified HRAs Now Permitted for Small Employers

04/04/17

The 21st Century Cures Act provides for qualified small employer health reimbursement arrangements. The IRS has now extended the time that a small employer needed to provide notice to employees.

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PGBC Requests Information for Multiemployer Plans

01/16/17

The Pension Benefit Guaranty Corporation (PBGC) has issued a request for information (RFI) concerning the "two pool" method for allocating withdrawal liability.

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Extension for Furnishing Forms 1095-B and 1095-C to Individuals

12/13/16

The IRS has announced a short delay in the furnishing of ACA reporting forms to individuals.

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2017 Health & Welfare Plan Limits

11/10/16

The IRS has released the health & welfare limits for 2017.

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IRS Announces 2017 Pension Limits

10/28/16

The IRS has released the pension limits for 2017.

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PBGC Announces 2017 Premium Rates

10/21/16

The PBGC has released the premium rates for 2017.

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Starting in 2017, Your Plan's Opt-Out Payment and Rules May Impact Penalties Under the Affordability Rules (However, the IRS Provides an Exception for Eligible Arrangements)

10/07/16

The IRS has proposed a regulation on the treatment of opt-out payments.

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PBGC Issues Final Rule for Premium Penalty Relief

10/03/16

The Pension Benefit Guaranty Corporation (PBGC) has finalized the relief for the penalties that apply for the late payment of premiums.

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IRS Simplifies Rules for Allowing Participants to Take Partial Lump-Sum Distributions

09/27/16

The IRS has modified their regulations to make it easier for a plan to pay part of the benefits as a lump sum and part as an annuity.

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Plan Administrators May Accept Self-Certification Waivers of 60-Day Rollover Requirement

09/13/16

The IRS has issued new guidance on waivers of the 60-day period for rollovers to eligible plans.

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Proposed Regulations on Deferred Compensation Plans Under Code 457

08/24/16

The IRS has proposed regulations concerning ineligible deferred compensation arrangements under Internal Revenue Code section 457(f).

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Substantial Changes to Form 5500 Reporting Proposed

08/03/16

The DOL, IRS, and the PBGC have proposed major changes to the reporting requirements on Form 5500 and related schedules.

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Nondiscrimination Rule Expands Administrative Practices, Notice/Language Requirements and Transgender Coverage for Certain Plans

07/22/16

The Office for Civil Rights in the Department of Health and Human Services has issued a final regulation under the Affordable Care Act on nondiscrimination in health programs and activities.

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Significant Changes to the IRS Determination Letter Program

07/19/16

The IRS has released a revenue procedure that makes changes in the determination letter program for qualified plans.

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Task Force Recommends Changes in Actuarial Standards for Pension Plans

07/14/16

The Actuarial Standards Board has released the report of its Pension Task Force, which recommends changes in the actuarial standards of practice with respect to defined benefit pension plans.

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DOL Increases Penalties for Violations of ERISA

07/08/16

The Department of Labor has increased the penalties that can be assessed for certain failures under ERISA.

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2015 PCORI Fee Payment Due by August 1, 2016

07/06/16

The Patient-Centered Outcomes Research Institute (PCORI) fees are due at the end of July.

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PBGC Proposes Regulation on Facilitated Mergers of Multiemployer Plans

06/28/16

The PBGC has proposed a new regulation on the mergers of multiemployer plans to reflect the changes made by the Multiemployer Pension Reform Act of 2014.

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PBGC Revises Annual Financial and Actuarial Information Reporting for Single-Employer Plans

06/06/16

The PBGC has revised its reporting rules for underfunded single employer plans (and plans that have unpaid contributions).

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Treasury Issues Final Suspension of Benefits Regulations under MPRA

06/01/16

The IRS has issued final regulations with respect to the suspension of benefits under the Multiemployer Pension Reform Act of 2014.

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Departments Finalize New Summary of Benefits and Coverage and Uniform Glossary

05/27/16

The Government has released final revisions to the Summary of Benefits and Coverage form and to the Uniform Glossary.

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Treasury Rejects Central States Suspension Application: But Many Misunderstand Reasoning

05/20/16

The Department of the Treasury issued a letter denying the application by the Central States, Southeast and Southwest Areas Pension Plan to cut benefits. Commentators have misunderstood a key aspect of the Treasury's reasoning.

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PBGC Increases Penalties for Failure to Provide Certain Notices

05/18/16

The PBGC has significantly increased the maximum penalties for failure to provide the PBGC certain notices.

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PBGC Proposes Relief for Penalties on Late Payment of Premiums

05/10/16

The PBGC proposes reduction in penalties for late premiums.

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GASB Issues Statement No. 82 - Pension Issues Amending GASB Statements No. 67, No. 68, and No. 73

04/18/16

The Governmental Accounting Standards Board (GASB) has released new Statement No. 82, which makes changes to Statements No. 67, 68, and 73.

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PBGC Reports Multiemployer Program Likely To Be Insolvent In 10 Years Without Large Premium Increases

04/01/16

The PBGC has released its latest report on the multiemployer insurance program.

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Proposed Nondiscrimination Relief for Closed Defined Benefit Plans

03/25/16

The IRS has proposed regulations that would modify the nondiscrimination requirements applicable to qualified plans. In particular, the proposed regulations would provide relief with respect to a "closed defined benefit pension plan" (a closed plan).

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Agencies Propose Revisions to Summary of Benefits and Coverage Template and Uniform Glossary

03/11/16

The Government has released proposed revisions to the Summary of Benefits and Coverage form and to the Uniform Glossary.

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FASB Proposed Changes to Accounting for Pension and Other Postretirement Plan Expenses

02/24/16

The Financial Accounting Standards Board (FASB) has released two exposure drafts that propose changes to the accounting for pension and other postretirement plan expenses.

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IRS Proposes New Normal Retirement Age Safe Harbors for Governmental Plans

01/29/16

The IRS has proposed regulations regarding the normal retirement age permitted under a qualified governmental plan.

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Comments on Proposed Changes to Regulations on Disability Claims Procedures Due January 19

01/15/16

The Department of Labor has proposed regulations that would change the claims procedures for disability benefits. There is only a short time period left to provide comments.

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PBGC Issues Final Partition Rule

01/15/16

The PBGC has issued a final regulation on the partitioning of multiemployer pension plans.

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Extensions for ACA 1094/1095 Information Reporting

01/04/16

The IRS announced extensions of the deadlines for filing information reporting forms under the Affordable Care Act (ACA) for 2015.

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New GASB Exposure Draft Issued

01/04/16

The Governmental Accounting Standards Board (GASB) has issued an exposure draft of a proposed statement addressing certain pension issues.

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IRS Issues Regulations on Funding for Single-Employer Pension Plans

09/17/15

The IRS has released final regulations for determining the minimum required contribution and quarterly contributions for single-employer defined benefit plans under the Pension Protection Act of 2006.

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Additional Excise Tax, i.e., "Cadillac Tax" Notice Requests Comments

09/11/15

Treasury and IRS have issued a second Notice regarding the excise tax on high cost employer-sponsored health coverage, or "Cadillac Tax."

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Voting Procedure for Suspension of Benefits

09/04/15

The Department of the Treasury and the Internal Revenue Service has just released regulations on the voting procedure in connection with a suspension of benefits under the Multiemployer Pension Reform Act of 2014.

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The Departments Revise Regulations for the Summary of Benefits and Coverage

09/04/15

The Departments of Labor, Health and Human Services, and the Treasury have revised the regulations for the summary of benefits and coverage.

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IRS Announces Major Changes in Determination Letter Program

08/05/15

The IRS has announced major changes to the determination letter program for individually designed qualified pension and profit-sharing plans.

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GASB Releases New Statements for OPEB Accounting and Non-Trust Pension Plans

07/01/15

The Governmental Accounting Standards Board has released new Statements 73, 74, and 75.

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Updated PCORI Fees Due by July 31

07/01/15

The PCORI fee is due at the end of July and the rate has increased.

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IRS and PBGC Issue Regulations under MPRA

06/22/15

Agencies issue rules for benefit suspensions and plan partitions under the Multiemployer Reform Act of 2014.

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New FAQs on Cost-Sharing Requirements for Certain Preventive Services

06/19/15

The Departments of Labor, Health and Human Services, and the Treasury have issued a new set of FAQs related to coverage of preventive services.

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EEOC Requests Comments on Proposed Amendments to Regulations to Accommodate Wellness Programs

06/11/15

The Equal Employment Opportunity Commission (EEOC) has proposed amendments to the Americans with Disabilities Act (ADA) and is requesting comments.

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GASB Approves New Statements for OPEB Accounting and Non-Trust Pension Benefits

06/05/15

The Governmental Accounting Standards Board has approved two new statements related to accounting for Other Postemployment Benefits.

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Benefit Suspensions Under the Multiemployer Reform Act

05/15/15

Learn more about this topic, and other timely compliance matters, in our most recent Client Advisory.

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"Cadillac Tax" Notice Requests Comments

03/31/15

The Department of Treasury and Internal Revenue Service have issued a Notice that lays out their possible approaches to implementing the 40% excise "Cadillac Tax" on the value of health benefits exceeding threshold amounts that takes effect in 2018. Those agencies are soliciting public input on the final shape of those regulations should take.

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Agencies Issue Request for Comments Under Multiemployer Pension Reform Act of 2014

02/20/15

The Department of the Treasury, the IRS, and the PBGC have formally requested comments with respect to certain provisions of the Multiemployer Pension Reform Act of 2014.

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Agencies Propose Revisions to Summary of Benefits and Coverage

02/11/15

Proposed changes in the required content of summary of benefits and coverage (SBC) documents issued by health plans and health insurers have been published by the relevant federal agencies. If the new regulations are adopted as proposed, they will require changes to SBCs issued in conjunction with health plan enrollment periods beginning on or after September 1st of this year.

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Agencies Proposed Amendments Include Limited Wraparound Coverage as "Excepted Benefits"

01/14/15

Agencies issue preliminary wraparound benefits definition for "Excepted Benefit" status.

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Multiemployer Pension Reform Act of 2014 Zone Status Changes

12/22/14

The Multiemployer Pension Reform Act of 2014 made important changes with respect to multiemployer plans. This pension alert discusses changes in zone status and certifications that will go into effect 2015.

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Multiemployer Pension Reform Bill Released

12/11/14

Legislative language for a multiemployer pension reform bill released in the House of Representatives.

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IRS Announces 2015 Pension Limits

10/24/14

The IRS has announced the cost-of-living (COLA) adjustments to various pension limits that will apply in 2015.

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Agencies Issue Amendments to Regulations on Excepted Benefits, i.e., Benefits Exempt from ACA Requirements

10/23/14

The Internal Revenue Service, Department of Labor, and Department of Health and Human Services have published amendments to the regulations regarding excepted benefits.

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Deadline for Health Plans to Acquire Unique Health Plan Identifier Fast Approaching

10/07/14

Under the Affordable Care Act and the Health Insurance Portability and Accountability Act, health plans that are "Controlling Health Plans" are required to obtain a unique health plan identifier from the Department of Health and Human Services.

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GASB's Exposure Drafts for OPEB Accounting: Comments to GASB Due by August 29, 2014

08/26/14

GASB is encouraging comments on their exposure drafts for OPEB accounting, which may have a significant effect on your financial reporting.

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Pension Provisions in Highway and Transportation Funding Act of 2014

08/13/14

Due to recently enacted legislation, single-employer pension sponsors need to make a decision soon on whether to change the interest rate used to determine minimum contributions effective for 2013 plan years or to defer required changes to affect plan years beginning in 2014.

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New Model COBRA Notice/Language Issued - Individuals Eligible for COBRA Have Special Enrollment Period

06/27/14

The Department of Labor (DOL) has updated their model COBRA notices and extended the time that current COBRA participants had to go into the Marketplace Health Insurance Exchanges.

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GASB Releases Exposure Drafts for OPEB Accounting and Non-Trust Pension Plans

06/20/14

The Governmental Accounting Standards Board (GASB) has released two exposure drafts related to accounting for Other Postemployment Benefits (OPEB).

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GASB Approves Exposure Drafts for OPEB Accounting and Non-Trust Pension Benefits

06/16/14

The Governmental Accounting Standards Board (GASB) has approved the release of exposure drafts related to accounting for Other Postemployment Benefits (OPEB).

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Recent Court Decision Could Affect Public Pension Plans

04/11/14

A recent ruling by a U.S. Court of Appeals concluded that requiring older pension participants to contribute more to help fund their benefits violated the Age Discrimination in Employment Act.

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Transitional Reinsurance Program Modified

04/09/14

Health and Human Services (HHS) has provided updated guidance on the Transitional Reinsurance fees implemented by the Affordable Care Act. Plans are now better able to determine the financial impact of these fees.

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New PBGC Premium Rules Require Attention, Action in Some Cases

04/03/14

The Pension Benefit Guaranty Corporation (PBGC) has revised its regulations on payment of premiums. This revision completes PBGC's recent effort to simplify the premium payment rules and provide plans with relief from penalties.

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PBGC Proposes Reporting Changes for Plans

02/24/14

The PBGC is proposing to change some reporting requirements for both multiemployer and single-employer plans.

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Comments Due on Proposed Regulation on Excepted Benefits, i.e., Benefits Exempt from ACA Requirements

02/19/14

Plan sponsors need to decide on or before February 24, 2014 whether they want to comment on the proposed regulation regarding excepted benefits.

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PBGC Proposes Reporting Changes for Multiemployer Plans

02/06/14

The Pension Benefit Guaranty Corporation (PBGC) has issued a proposed regulation lessening administrative and reporting burdens for mergers of multiemployer plans and for some terminated multiemployer plans.

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GASB Releases Statement 68 Implementation Guide

02/03/14

The Governmental Accounting Standards Board (GASB) has released the Guide to Implementation of GASB Statement 68 on Accounting and Financial Reporting for Pensions.

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GASB 67 Implementation Deadline Nears: Are Pension Plans Prepared?

01/30/14

The effective date of the new Governmental Accounting Standards Board Statement No. 67 (GASB 67) is upon us! This Advisory will review the new disclosures as well as related issues and decisions that need to be made in advance of the preparation of the first statement.

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PBGC Premium Changes Require Sponsor Analysis, Action

01/07/14

Single-employer and multiemployer pension plan sponsors face important changes with respect to their PBGC premiums.

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IRS Announces 2014 Pension Limits

11/06/13

The IRS has raised the basic dollar limits affecting defined benefit and defined plan contributions, leaving one unchanged.

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SEC Approves Registration Rules for Municipal Advisors: Exempts Public Sector Employees and Retirement Board Members

10/04/13

The SEC has expanded its oversight of advisors to public entities with respect to their issuance of bonds, by requiring such advisors to register with the independent agency. But in a reversal from temporary rules issued in 2010 under the Dodd-Frank Act, public sector employees and retirement board members are exempt from that requirement.

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October 1, 2013 Deadline to Notify Employees About Exchanges

09/09/13

This Alert reminds employers that the Exchange Notices must be issued to employees in less than 4 weeks. The Health Alert provides the details and the attachments are the model notices.

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PCORI Fees Are Due at the End of the Month

07/02/13

Patient-Centered Outcomes Research Institute (PCORI) fees are due. Form 720 with payment needs to be filed by July 31, 2013.

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GASB Releases Statement 67 Implementation Guide

07/01/13

The Governmental Accounting Standards Board (GASB) has released the Guide to Implementation of GASB Statement 67 on Financial Reporting for Pension Plans.

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IRS Proposes Rules on Determining Minimum Value for Health Plans

05/21/13

The IRS issued a proposed regulation on May 3<sup>rd</sup> on how to determine whether a health plan provides "minimum value."

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Updating Your Funding Strategy in the Face of New GASB Standards

05/16/13

In light of GASB's recent significant changes in pension disclosure standards, it is time for sponsors to review their funding policies. This Client Advisory provides an overview of funding policies, considerations and components of establishing a policy, and recently issued and pending guidance.

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P&I APP Article Updated

05/03/13

A recent article in Pensions & Investments highlights the adjustable pension plan (APP), but the original print version of the article incorrectly stated that the plan design was entirely created by a single Cheiron consultant. The APP which Cheiron helped develop, and continues to foster along with others, is the result of a collaborative project that prominently included David Blitzstein and the UFCW, Skip Halpern, Area President of Gallagher Fiduciary Advisors, LLC, Barry Slevin, of the law firm Slevin & Hart, and a number of our clients. Recognition of these other players in the creation of this concept is critical to us in telling not only the story of the concept's origin, but also the nature of innovation in pension design to maintain sustainable defined benefit plans.

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IRS Proposes Regulations on "Play or Pay" Rules

02/28/13

The proposed "play or pay" IRS regulations provide long-awaited guidance on the excise tax under the employer "shared responsibility" provisions of the Patient Protection and Affordable Care Act.

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March 1, 2013 Deadline to Notify Employees about Exchanges Postponed; HRA Guidance Provided

01/25/13

The Department of Labor (DOL) announced yesterday that the March 1, 2013 deadline to notify employees about Exchanges is delayed until later in the year.

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IRS Finalizes Fee Calculation and Reporting for Patient-Centered Outcomes Research Institute Fee for Health Insurance Plans.

12/21/12

The Internal Revenue Service (IRS) published final regulations on December 6, 2012, concerning the calculation and reporting of fees with respect to health insurance plans.

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HHS Issues Proposed Rules for Transitional Reinsurance Program

12/13/12

The Department of Health and Human Services (HHS) released a proposed regulation concerning certain benefit and payment parameters for the Insurance Exchanges starting 2014.

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Cheiron Authors Cover Story

11/06/12

A feature article explaining the creative new Adjustable Pension Plan concept that has been developed and advanced by Cheiron was published as the cover story of the November issue of the International Foundation's <i>Benefits Magazine</i>.

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Health Care Reform: What's Next

07/11/12

The Supreme Court's recent ruling essentially upholding the Affordable Care Act refocuses Employer-Sponsored Health Plans on the tasks ahead required to comply with the 2010 law. The attached Health Advisory highlights key short-term action steps as well as issues for consideration for 2013 and beyond.

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Pension Provisions in Moving Ahead for Progress in the 21st Century

07/09/12

On Friday, July 6, 2012, President Obama signed the "Moving Ahead for Progress in the 21st Century Act," which cleared Congress a week ago. As we reported then, the law contains important provisions impacting pension funding, disclosures and PBGC administration, and other matters.

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Pension Provisions Included in Surface Transportation Bill

06/29/12

Today Congress passed the Surface Transportation bill, which contains two important changes for pension plans: Interest rate stabilization for single-employer plans and an increase in PBGC premiums. Please see the attached Pension Alert for details.

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GASB Approves New Accounting Standard for Pension Plans

06/27/12

The Governmental Accounting Standards Board (GASB) has approved two new accounting standards for public pension accounting and financial reporting, GASB 67 and 68. Although the full text of the final statements will not be available until August, the attached description and analysis is offered as preliminary guidance based on our understanding of decisions the Board made since the Exposure Drafts were issued.

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Agencies Request Comments on ACA Regulations/Notices/Request for Information

05/16/12

The Internal Revenue Service (IRS) has issued one proposed regulation, three notices, and a request for information related to the Patient Protection and Affordable Care Act (the Affordable Care Act or ACA).

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IRS Takes Steps to Resolve Issues Related to Normal Retirement Age under a Governmental Plan

04/24/12

The IRS regulations on normal retirement age have raised many issues for governmental plans. Notice 2012-29 announced intended changes that represent a significant step toward resolving those issues.

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Final Summary of Benefits and Coverage (SBC) Rules Issued

02/21/12

The Department of Health and Human Services (HHS), the Department of Labor (DOL), and the Internal Revenue Service (IRS) released its final regulations on requirements of a written summary, referred to as <b>&ldquo;the summary of benefits and coverage&rdquo;</b> or the &ldquo;SBC&rdquo; that group health plans or health insurance issuers must distribute. The SBC is intended to be a standardized summary in order to make plans both easy to understand and to compare.

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Two Important ERRP Deadlines

01/11/12

Two Important ERRP Deadlines: 1. CMS Requests ERRP Survey to be Completed This Week 2. Error-Free Claims must be Submitted by March 30, 2012

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IRS Deadline for Filing New SSA Form

12/13/11

Deadline looms for filing new IRS form for departed, vested pension plan participants.

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IRS Issues Sample Amendment for Section 436 and Postpones Date for Amending Single-Employer Pension Plans

12/13/11

IRS issues sample amendment for single-employer plans to use to implement the benefit restrictions of IRC section 436 that apply to underfunded pension plans.

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A Better Answer to the Actuarial Discount Rate Debate

11/18/11

Cheiron&rsquo;s Gene Kalwarski and Bill Hallmark have published an article in the current issue of the International Foundation&rsquo;s <i>Benefits Magazine</i>. Their article presents a fresh perspective on actuarial discount rates and understanding pension risk. You may read the article here.

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IRS Issues Draft Governmental Plan Regulations

11/10/11

The Internal Revenue Service has issued a draft regulation attempting to define what constitutes a governmental plan under ERISA. This is the first regulation issued to date. Distinctions between the law's treatment of governmental and nongovernmental plans are very significant. Therefore, plans that assume they fit into one category or another should take note of these proposed rules under Section 414(d) in this Pension Alert.

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GASB 27 Exposure Draft on Employer Accounting and Financial Reporting for Pensions: A Detailed Advisory

10/28/11

GASB's Statement 27 on financial reporting for public pension represents a major overhaul of its prior rules, and plan sponsors need to start considering the effect on the reporting by the plans. This Client Advisory is a detailed follow-up to earlier communications from us on this topic. The Advisory offers a detailed review of the principles behind GASB 27, its specific requirements and the steps public plan sponsors must take to be ready for compliance when the new accounting standards takes effect.

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GASB 25 Exposure Draft on Financial Reporting for Public Pension Plans: A Detailed Advisory

10/20/11

GASB's Statement 25 on financial reporting for public pension represents a major overhaul of its prior rules, and plan sponsors need to start considering the effect on the reporting by the plans. This Client Advisory is a detailed follow-up to earlier communications from us on this topic. The Advisory offers a detailed review of the principles behind GASB 25, its specific requirements, and the steps public plan sponsors must take to be ready for compliance when the new accounting standards take effect.

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FASB Issues New Disclosure of Requirements for Employers Participating in Multiemployer Plans

10/18/11

Publicly traded firms that contribute to multiemployer plans will soon be subject to new FASB disclosure standards, and private firms will fall under the new rules a year later.

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Deadline for Providing Notice of Creditable Coverage Shortened

09/21/11

As a result of the change in the annual coordinated election period, the due date for providing notice of creditable coverage to participants and beneficiaries in health plans has changed from November 15 to October 15.

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Agencies Propose Summary of Benefits and Coverage (SBC) Rules

08/25/11

The Department of Health and Human Services, the Department of Labor, and the Internal Revenue Service have released proposed regulations with respect to the disclosure of the summary of benefits and coverage (SBC) by a group health plan or health insurance issuer.

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HHS Announces Preventive Health Care for Women

08/05/11

The Department of Health and Human Services (HHS) has just announced additional preventive care services for women covered under "non-grandfathered" health care plans.

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PBGC Relief Expired; Actions by FASB and the Courts

08/01/11

Filing Schedule R for Form 5500 may be tougher as PBGC relief has expired. In other news, recent actions by FASB and the U.S. Court of Appeals for the Third Circuit have important implications for pension and welfare plans.

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GASB’s Exposure Drafts on New Public Pension Accounting Released July 8, 2011: New Rules Eliminate ARC and Disclose Pension Liability on Balance Sheet

07/12/11

The Governmental Accounting Standards Board (GASB) has issued Exposure Drafts relating to pension accounting and financial reporting.

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HHS Announces Final Annual Waiver Deadline of September 22, 2011

07/01/11

The Department of Health and Human Services (HHS) has just announced that it is ending the process for obtaining waivers of the annual limit restrictions on health plans.

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Supreme Court Underscores Importance of Accuracy in Communications to Plan Participants

06/02/11

Ruling in CIGNA case suggests broad remedies available for inaccurate statements.

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What’s Next for Health Plans? Cheiron Analyzes the Key Trends

02/10/11

Cheiron&rsquo;s 2011 health care benefit review and outlook Client Advisory reports on several interesting developments on the health care and health benefits front. In it you will find a briefing on health care cost and plan design trends, an update on the implementation of the Patient Protection and Affordable Care Act, and highlights of important medical advances over the past year.

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Funding Relief Provisions Clarified; Election Deadline Jan. 31 for 2009, 2010 Calendar Plan Years for Single-Employer Plans

01/20/11

Deadlines arrive at the end of the month for elections of funding relief for single employer pension plans for 2009 and 2010 plan years.

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Plan Funding and Benefit Restrictions: An Analysis of Complex Interactions Among Certain Provisions in Regulations Under Tax Code Sections 430 and 436

12/21/10

Discusses provisions and interactions.

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New IRS Guidance on Pension Funding Relief Lays Out Options for Plan Sponsors but Requires Careful Attention to Timing

12/03/10

IRS guidance lays out path for pension funding relief.

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Multiemployer Plan Companies Facing Greater Disclosure Demands Under New FASB Proposal

09/21/10

Companies participating in multiemployer plans that provide pension and/or other postretirement benefits will soon face additional financial disclosure requirements if a FASB exposure draft issued on Sept. 1 is finalized.

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GASB moving towards radical overhaul of public pension accounting

08/31/10

"Preliminary Views" issued by GASB on pension accounting would, if adopted, represent a radical departure from past practice and bring governmental employers much closer to the FASB standards governing private employers. Public employers should anticipate that the accounting rules under consideration would have a significant impact on their balance sheet and income statements.

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Analysis from Cheiron: The New Paradigm for Healthcare Financing

07/26/10

The Health Care Reform enacted in early Spring 2010 creates a new paradigm for America's healthcare financing. Since the legislation was adopted, regulations have been forthcoming at a rapid pace. These regulations help the industry.

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Multiemployer funding relief enacted; Trustee decisions required

07/08/10

In a surprising turn of events, Congress has passed, and the President has signed, pension funding relief, using the Senate version passed in March.

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GASB’s “preliminary views” on new public pension accounting rules point toward significant increases in most employers’ reported liabilities

07/08/10

The Government Accounting Standards Board (GASB) has issued its Preliminary Views on major issues relating to pension accounting and financial reporting by employers, and a Plain-Language Supplement.

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HHS Issues Interim Final Rule on Early Retiree Reinsurance Program

05/13/10

On May 5, 2010, the Department of Health and Human Services (HHS) released an "interim final rule with comment period" to implement an Early Retiree Reinsurance Program as required by the Patient Protection and Affordable Care Act (PPACA) of 2010.

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Health Plans Confronting Cost Pressures, Reform Prospects, Medical Advances

02/23/10

Cheiron's 2010 health care benefit review and outlook Client Advisory provides a briefing on health care cost and plan design trends and a report on the progress of health care reform, other legislative and regulatory developments, and highlights of important medical advances over the past year.

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DOL Regulations Spell Out Penalties for Noncompliance by Multiemployer Plans in Developing Funding Plan

03/12/10

The Department of Labor ("DOL") issued a final regulation for imposing statutory civil penalties on Trustees of multiemployer plans in critical or endangered status that fail to adopt a Funding Improvement or Rehabilitation Plan by the statutory deadline.

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DOL Issues Final Rules on Multiemployer Plan Document Disclosure; Regulations Effective April 1

03/12/10

The Department of Labor ("DOL") issued a final regulation under ERISA section 101(k) requiring the plan administrator of a multiemployer plan to provide copies of certain actuarial and financial documents after receipt of a written request.

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Welfare Plan Change Impacting Pension Benefits; Violates Anti-cutback Rule, Appeals Court Holds

02/24/10

The United States Court of Appeals for the Third Circuit has ruled that an amendment to a welfare plan that had the effect of reducing indirectly the value of an optional form of distribution from a pension plan violated the anti-cutback provisions of ERISA. The Court's precedential opinion in <i>Clement Battoni, Jr. et al. v. IBEW Local No. 102 Employee Pension Plan, et al.</i> was released Feb. 5, 2010.

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Deadline Nears for Multiemployer Plans to Submit Determination Letter Applications

09/08/09

Learn more about this topic, and other timely compliance matters in our most recent Client Advisory.

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New PBGC Regulation Offers Multiemployer Plans Additional Options for Withdrawal Liability

01/30/09

The PBGC has published a final regulation that implements changes made by the Pension Protection Act of 2006 (PPA) in withdrawal liability calculations.

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New Pension Relief Law a Mixed Bag for Plan Sponsors

12/29/08

The "Worker, Retiree, and Employer Recovery Act of 2008," amends the 2006 Pension Protection Act ("PPA") to provide limited relief from the drastic contribution increases that many plan sponsors are facing. The impact of the new law may vary significantly from one plan to the next.

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IRS Hearing Highlights Unresolved PPA Compliance Issues

09/08/08

Proposed IRS regulations governing "endangered" and "critical" plans have left many questions unanswered, as commentators made clear at a recent IRS hearing on those rules. Yet financially stressed multiemployer pension plans must now begin complying with special funding rules laid out in the Pension Protection Act of 2006, despite that lack of clarity. Insight is offered on how to navigate some of that uncertainty until all issues are resolved.

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IRS Issues Proposed Regulations on Certification of Funding Status for Multiemployer Plans

04/01/08

The regulation is basically a restatement of the law and leaves unanswered many thorny questions regarding development of funding improvement and rehabilitation plans. It does, however, clarify certain issues for those plans that sent out early notices of expected critical status and the use of pre-PPA extensions of the amortization period for determining whether the plan is critical.

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Endangered and Critical Plans: Sorting Through the Options - Winter 2008

03/13/08

Review concrete illustrations of funding improvement plans for "endangered" multiemployer pension and rehabilitation options for "critical" plans under the Pension Protection Act.

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Read Some Real-World Examples Illustrating Possible Responses Some Sponsors are Considering to the Prospect of Adverse Certification in 2008 - Summer 2007

03/13/08

Read about some possible approaches, using real case study examples, to avoid having red flags waved over your pension when PPA's first certification requirements kick in next year.

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Navigating the PPA’s Special Funding Rules and Ambiguities - Spring 2007

03/13/08

The Pension Protection Act's new funding rules for multiemployer plans become effective in 2008. However, important steps can be taken this year to address the new requirements.

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Free Drugs? - Fall 2006

03/13/08

Some of the nation&rsquo;s largest retailers are battling it out with cheap and even some free prescription drugs to capture consumer market share.

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Pension Protection Act for Multiemployer Plans

03/13/08

View a summary of Key Provisions Affecting Multiemployer Defined Benefit Plans as of September, 2006.

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Congress (Finally) Clears Sweeping Pension Legislation

03/13/08

Both houses of Congress have adopted pension legislation with major implications for multiemployer and single employer defined benefit plans, as well as defined contribution plan sponsors. For pension sponsors, new funding rules and standards are likely to increase plan volatility.

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Setting a Withdrawal Liability Policy that Meets Your Strategic Objectives - Summer 2005

03/13/08

With the emergence of large unfunded liabilities and a shrinking base of contributing employers, multiemployer pension trustees need to ensure an appropriate withdrawal liability determination method is in place.

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Deadlines Near for Key Decisions on Retiree Drug Benefit Strategy - Spring 2005

03/13/08

Plan Sponsors should understand their options and their potiential impact in order to take full advantage of Medicare&rsquo;s new prescription drug benefit program.

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What Governments Should Know About the GASB Postemployment Benefit Standards - Fall 2004

03/13/08

The Governmental Accounting Standards Board has finally released its new financial statements governing financial reporting for postemployment benefit plans other than pension plans.

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Pension Funding Equity Act of 2004 - Spring 2004

03/13/08

Congress finally has responded &ndash; well, sort of, anyway &ndash; to the appeals of financially strained pension sponsors, in the recent enactment of the Pension Funding Equity Act of 2004. The new law offers relief to some plans and empty symbolism to others.

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New Medicare Law: Opportunities, Policy Questions for Employers - Winter 2004

03/13/08

The recent Medicare Act has significant implications &ndash; and possible savings opportunities &ndash; for employers that sponsor health plans.

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Does Your Health Insurer Really Need That Large Rate Increase? - Fall 2003

03/13/08

Based on what Cheiron's consultants have been uncovering, it would be a very costly mistake for health plan sponsors not to have their renewal proposals from carriers put under the microscope.

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Looking Ahead for the Perfect (Pension) Storm’s Next Move

03/13/08

With the perfect storm raging, it&rsquo;s essential to know that your pension&rsquo;s pilot is equipped with all the necessary skills and navigational tools to determine whether a new course is indicated, and if so, which one to take.

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Tired of Feeling the Squeeze?

03/13/08

It&rsquo;s tough enough for plan sponsors to deal with eroding pension assets and a sluggish economy. Adding insult to injury is an obsolete, punitive and internally contradictory regulatory overlay that makes it harder for sponsors to navigate the economic storm they face. It is essential, therefore, for sponsors to raise their voices today to get some relief, or face near-certain drowning.

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