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Presentation
given by Ron Dutton
of R.JDutton, Inc.,
on June 25, 2009.
If you would like a copy of this presentation, contact RJDutton.
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Earlier this year, the IRS finalized regulations it had proposed in November of 2007 on the subject of automatic enrollment in salary deferral plans. These final regulations respond to a number of comments on the proposed regulation.
As of January 1, 2009, most group health plans became subject to the Mandatory Medicare Secondary Payer Reporting Program. On March 16, 2009, the Centers for Medicare and Medicaid Services ("CMS") issued the latest version ("Version 2.2") of the Group Health Plan User Guide for use by responsible reporting entities ("RREs") under this Program.
Part 4 of title I of the Employee Retirement Income Security Act of 1974 ("ERISA") sets forth the rules that apply to fiduciaries of ERISA-covered employee benefit plans.
The economic recession has caused many employers to reevaluate their severance policies. We find that employers often strive to ensure that those policies do not amount to enforceable promises to provide similar benefits to similarly situated employees, but rather are non-ERISA, ad hoc arrangements.