May 15, 2020 |
In response to the COVID-19 crisis, many employers have been faced with the difficult task of taking short-term measures to preserve long-term viability. Measures taken include layoffs, furloughs, reduced work schedules, and work-from-home arrangements. These actions have ripple effects that impact employer-sponsored benefits provided to employees. In addition, responsive measures adopted under the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and by the Internal Revenue Service (IRS) and Department of Labor also impact employer-sponsored benefits.
Importantly, employers must be aware of actions required, now or in the future, to effectuate any required or optional benefit plan changes. For example, qualified retirement plan amendments required under the CARES Act must be adopted by the last day of the first plan year beginning on or after January 1, 2022 (January 1, 2024 for government plans). In either case and in the interim, a plan must be in operational compliance with any forthcoming amendment.
Pepper Hamilton’s Employee Benefits and Executive Compensation attorneys have joined forces with our future colleagues at Troutman Sanders to put together this reference guide for employers to assist you in meeting your current and future obligations.
• Rebecca Alperin, Of Counsel
• Evelyn Small Traub, Partner
• Lynda M. Crouse, Partner
• Emily D. Zimmer, Partner
• Lisa K. Shallue, Counsel
• Christopher Stock, Associate
• Mamta K. Shah, Partner
Compliments of Pepper Hamilton – a member of the EACCNY.