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DOL Information Letter Provides Companion Guidance to IRS Notice 2014-66

The U.S. Department of Labor (the ?Ç£DOL?Ç¥) released an Information Letter coincident with the IRS?ÇÖs issuance of Notice 2014-66, confirming that the inclusion of unallocated deferred annuity contracts as fixed income investments within a series of TDFs as described in Notice 2014-66 would not cause the TDF series to fail to comply with the qualified default investment alternative rules applicable to TDFs under ERISA. The selection of unallocated deferred annuity contracts within a TDF series will satisfy the DOL?ÇÖs annuity selection safe harbor under ERISA (the ?Ç£Annuity Safe Harbor?Ç¥) if the plan sponsor prudently selects and appropriately monitors the investment manager and the investment manager meets each condition of the Annuity Safe Harbor. Plan sponsors of defined contribution plans offering TDFs that include deferred annuities for older participants should carefully review Notice 2014-66 and the DOL Information Letter to ensure that their TDF arrangements meet the conditions discussed in each.… Continue Reading

CMS Announces Indefinite Delay in Enforcement of HPID Regulations

The Centers for Medicare & Medicaid Services (?Ç£CMS?Ç¥) announced the indefinite delay of its enforcement of the requirement that health plans obtain and use a Health Plan Identifier (?Ç£HPID?Ç¥) in HIPAA transactions. Certain health plans had been required to obtain a HPID by November 5, 2014. The enforcement delay applies to all HIPAA covered entities, including health plans and healthcare providers. The CMS announcement is available?áhere.

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