Monday Briefing – Consolidated Omnibus Appropriations Act, Fiduciary Rule, HIPAA Audits, Determination Letters

The “Consolidated Appropriations Act, 2016″ bill has been signed.  ( (CNN) (GPO). We discussed the bill briefly last week, but a few things are worth repeating:
  • The Cadillac tax gets delayed to 2020.
  • Full speed ahead for the DOL’s fiduciary rule. That’s in spite of some pretty heavy lobbying.
  • No changes making it easier for sponsors of open MEPs. This gets more significant in light of the DOL’s recent Interpretive Guidance on state-sponsored retirement plans. Watch for Part 2.5 of our series on these state initiatives later this week.
It’s time to say Aloha. (Chicago Sun-Times)
Here are a few things we think about when we are thinking about year-end:
  • ACA compliance get’s real in 2016. The so-called employer mandate rules required offers of coverage to 70% of your full time employees in 2015. That number goes to 95% in 2016. (IRS) (questions 25 & 37) And the penalties can get big.
  • And don’t forget about HIPAA. The Department of Health and Human Services Office of Civil Rights expects to begin its second phase of its HIPAA audit program in 2016. Having been through one of the early pilot programs, we can tell you these things are intense.  (HHS Office of Inspector General)
  • And we don’t want your qualified retirement plans to feel neglected. 2016 may be your last chance to apply for an IRS determination letter. It’s time to think about whether you want one more of those “suitable for framing” determination letters from the IRS. (IRS Announcement 2015-19)
  • Eight things ALEs should know about information reporting and health coverage offers. (IRS)

Bob Seng

With plenty of experience in private practice and as an Assistant General Counsel for Pay & Benefits in a Fortune 50 Company, Bob understands that employee benefits law isn’t for everyone. That’s why he takes pride in listening carefully and responding with clear answers and advice that can be followed by busy clients.

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