July 27th, 2011
In September of 2010, the Financial Accounting Standards Board (FASB) issued an exposure draft proposing new financial disclosure requirements for employers who contribute to multiemployer pension and health plans. The original FASB proposal required the disclosure of a significant amount of information — including an estimate of withdrawal liability — for employers participating in multiemployer pension plans.
At its July 27, 2011 Board meeting, the FASB made its final decision regarding a significantly reduced financial disclosure for employers participating in multiemployer plans. The revised FASB proposal eliminates the withdrawal liability disclosure and all disclosures for retiree health and welfare plans, as well as a number of other items that would be extremely burdensome for both employers and the plans to which they contribute. The revised disclosure focuses on contributions to the plans, the plans’ funding zones, and other information that should be available from the employer’s records, eliminating the need to request special calculations and other information from the plan administrators.
The FASB’s July 27, 2011 press release summarizing the final decision regarding multiemployer plan disclosures is posted on the FASB website. A final new accounting standard, documenting the decision reached at the July 27th meeting is expected by mid-September. The new standard will be effective for fiscal years ending after December 15, 2011 for public companies, and one year later for non-public companies.
Beginning last fall, Horizon Actuarial Services worked closely with a coalition of employers, financial statement users, and plan trustees to meet with, and educate, the FASB about the special nature of multiemployer plans and the need for a more workable financial disclosure. The FASB’s decision to simplify the disclosure requirements is a significant victory for multiemployer plans, contributing employers and participating unions.
Please contact your Horizon Actuarial consultant for additional information or if you have any questions.
Posted in Health & Welfare Issues, News, Pension Issues | Comments Off
June 24th, 2011
The IRS has issued guidance regarding Form 8955-SSA, which is the successor to the Schedule SSA of the Form 5500. Form 8955-SSA is the form to be used to satisfy the reporting requirements of section 6057(a) of the Code for plan years beginning after December 31, 2008. Form 8955-SSA should not be filed as part of the Form 5500.
Similar to its predecessor, the Form 8955-SSA is due by the last day of the seventh month following the last day of the Plan Year (plus extensions if applicable). An extension can be filed using the Form 5558, which is the same form used to extend the Form 5500.
There are special instructions for the 2009 and 2010 Plan Year filings. The due date for the 2009 and 2010 forms are the later of the due date for the 2010 form or January 17, 2012.
In addition, plan administrators may use a separate 2009 Form 8955-SSA to report information for the 2010 Plan Year or combine the information for the 2009 and 2010 Plan Years on a single 2009 Form 8955-SSA.
Instructions for the form can be found at: http://www.irs.gov/pub/irs-pdf/i8955ssa.pdf
The form itself can be found at: http://www.irs.gov/pub/irs-pdf/f8955ssa.pdf
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June 17th, 2011
The Department of Health and Human Services (HHS) announced that it will stop accepting applications after September 22, 2011 waivers from the Patient Protection and Affordable Care Act (PPACA) requirements that plans must offer a certain minimum dollar coverage amount for essential benefits each year. This applies to from sponsors of “limited benefit” health care or “mini med” plans. Plan sponsors who have already received waivers – including those whose waivers have not yet expired – have until September 22, 2011 to seek an extension.
The waivers under the extension will now last through the end of 2013 if plan sponsors comply with certain requirements such as submitting information about their plans and ensuring that participants understand the limits of the coverage. Prior to this guidance, waivers lasted only one year. No annual dollar limits on essential health benefits are permitted beginning in January 1, 2014.
The application materials are available online at: CCIIO: The Center for Consumer Information & Insurance Oversight.
This is a summary of the guidance. A more detailed explanation can be found on the Towers Watson website.
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Horizon Actuarial Services, LLC is an independent company and is not affiliated with Towers Watson.
Posted in Health & Welfare Issues, News | Comments Off
June 7th, 2011
In September of 2010, the Financial Accounting Standards Board (FASB) issued an Exposure Draft proposing new financial disclosure requirements for employers who contribute to multiemployer pension and health plans. The original FASB proposal required the disclosure of a significant amount of information — including an estimate of withdrawal liability — for employers participating in multiemployer pension plans.
At its May 31, 2011 Board meeting, the FASB reached a tentative decision regarding a significantly reduced financial disclosure for employers participating in multiemployer plans. The revised FASB proposal eliminates the withdrawal liability disclosure as well as a number of other items that would be extremely burdensome for both employers and the plans to which they contribute.
A summary of its May 31, 2011 Board meeting and the tentative revised proposal is posted on the FASB website.
The FASB’s action is an encouraging sign. However, some members of the Board are still advocating for additional disclosures. Horizon Actuarial Services is working closely with a coalition of employers, financial statement users, and plan trustees to bolster support among the FASB Board members for the more limited disclosure tentatively agreed to at the May 31 meeting. Horizon participated in a conference call with FASB staff earlier this week to address the coalition’s remaining concerns about additional multiemployer plan disclosure. The coalition is also requesting one more meeting with FASB Board members before the FASB takes final action, which could happen as soon as the end of June.
Please contact your Horizon Actuarial consultant for additional information or if you have any questions.
Posted in Health & Welfare Issues, News, Pension Issues | Comments Off
May 31st, 2011
Stephanie Patrick, a consulting actuary in Horizon’s Atlanta office, recently completed the educational requirements necessary to earn the designation of Fellow of the Society of Actuaries.
Congratulations (belatedly) to Stephanie on this great accomplishment!
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May 31st, 2011
Ben Ablin, an associate actuary in Horizon’s Washington, DC office, recently completed the educational requirements necessary to earn the designation of Enrolled Actuary.
Congratulations to Ben on this great accomplishment!
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May 27th, 2011
Sponsors of group health plans are required to notify annually individuals who are eligible for Medicare Part D as to whether the drug coverage they have is creditable or non-creditable.
The Centers for Medicare and Medicaid Services (CMS) have made two changes to this requirement:
1. CMS has issued new model disclosure notices that are to be used after April 1, 2011. The model notices, in both English and Spanish, can be found on the CMS website.
2. Beginning in 2011, the Patient Protection and Affordable Care Act (PPACA) changed the Medicare enrollment period, so the disclosure notice must now be sent to participants a month earlier. In the past, the Medicare enrollment period was November 15 through December 31, and the notice had to be given out by November 15. PPACA changes the enrollment period to October 15 through December 7. Accordingly, creditable coverage notices must now be sent by October 15.
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April 6th, 2011
The IRS has issued Notice 2011-28 with guidance for employers on Form W-2 reporting of the cost of their employer-sponsored group health plan coverage for employees as required under the Patient Protection and Affordable Care Act (PPACA).
Compliance is required beginning with the Form W-2 that will cover the 2012 year (delivered to employees in January 2013). Reporting for years prior to 2012 is optional. Several transition rules provide temporary reporting relief with respect to some types of health coverage (e.g., HRAs), for small employers (file fewer than 250 W-2s), and for multiemployer plans.
The guidance covers:
* Transition relief
* Employers subject to reporting
* Methods of reporting
* Aggregate cost of applicable employer-sponsored coverage
* Cost of coverage required to be included in the aggregate reportable cost
* Methods of calculating the cost of coverage
* Other issues relating to calculating the cost of coverage
This is a summary of the guidance. A more detailed explanation can be accessed on the Towers Watson website.
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Horizon Actuarial Services, LLC is an independent company and is not affiliated with Towers Watson.
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April 6th, 2011
Effective May 6, 2011, the Department of Health and Human Services (HHS) will no longer accept new applications for participation in the Early Retiree Reinsurance Program (ERRP) due to the availability of funding. If a plan sponsor who have yet to decide whether to participate in the ERRP will need to make a decision and file the appropriate application by May 5, 2011.
This application deadline has no affect on currently approved applications.
http://www.errp.gov/newspages/20110401-applications-acceptance.shtml
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April 6th, 2011
On April 5th, the Senate approved the bill approved by the House in early March – the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (H.R.4) – to repeal the PPACA provision that requires businesses to issue a Form 1099 to all payees who receive $600 or more in a year.
President Obama is expected to sign it into law.
http://www.whitehouse.gov/blog/2011/04/14/repealing-1099-reporting-requirement-big-win-small-business
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