The IRS Retirement Plan Determination Letter Program – The IRS Taketh and Then Giveth (Some Transition Guide)
Marvin "Bucky" Swift • January 8, 2016
Last July, in Announcement 2015-19 , the IRS announced that it was terminating its determination letter program for individually designed qualified retirement plans, other than for new or terminating plans. This week, in Notice 2016-03 the IRS provided us with specific transition guidance on the winding down of its program. Specifically, the IRS announced that:
- Controlled groups and affiliated service groups that maintain more than one plan are permitted to file determination letter requests during the “Cycle A” period beginning February 1, 2016 and ending January 31, 2017, only if the Cycle A election for the group was made by January 31, 2012;
- The expiration dates included in determination letters issued before January 4, 2016 are no longer operative (the IRS plans on issuing guidance to clarify when an employer can rely on its determination letter after a subsequent change in the law or plan amendment);
- To facilitate the plan sponsor’s transition from an individually designed plan to a pre-approved plan, the deadline for an employer to adopt a pre-approved defined contribution plan and to apply for a determination letter is extended from April 30, 2016 to April 30, 2017 (other than a plan that is adopted as a modification and restatement of a pre-approved defined contribution plan that was maintained before January 1, 2016).
If you have any questions about the determination letter process or the transition guidance, please do not hesitate to contact any of the attorneys in the Employee Benefits and Executive Compensation Practice Group at Snell & Wilmer.
Employee burnout has become an epidemic in today’s modern workplace. So much so that the World Health Organization (WHO) officially recognizes it as an “occupational phenomenon.”1
While many used to consider mounting workplace stress an individual employee problem, these days, it’s become an employer’s responsibility to prevent burnout before it hurts productivity and business performance—not to mention your employees’ physical and mental health.
Luckily, you can prevent burnout from affecting your workforce in several ways. This article will explore the causes and signs of employee burnout and the steps you can take to create a positive work environment where employees feel safe from toxic stress levels.
If you're a small business owner, you may have heard of the acronym PCORI and the fees that come with it. But what is PCORI, and how does it apply to your organization?
Under the Affordable Care Act (ACA), sponsors of self-insured health plans must pay a fee to fund the federal Patient-Centered Outcomes Research Institute (PCORI). PCORI is an independent organization the ACA created to conduct research to help healthcare consumers make better decisions for their specific needs and outcomes. It also performs research related to clinical effectiveness.
Employers offering a self-insured medical reimbursement health plan, such as a health reimbursement arrangement (HRA), must pay this fee by July 31 each year via Form 7201. This fee was initially set to expire in 2019, but Congress extended it through September 30, 20292, due to the Further Consolidated Appropriations Act of 20203.
