While not exactly a Thanksgiving “miracle,” many retirement plan sponsors were no doubt thankful for the IRS’ recent issuance of proposed regulations (the “Proposed Regs”) addressing changes to the Code §401(k) and 403(b) plan hardship withdrawal rules enacted as part of the Bipartisan Budget Act of 2018 (the “Act”). The Proposed Regs answer several questions raised by the Act, and provide plan sponsors with significant flexibility in how (and when) they implement the changes.
The Social Security Administration (SSA) recently announced that, by spring 2019, it will begin notifying each employer (and third-party payroll company) that has submitted at least one Form W-2 that contains name and Social Security Number (SSN) combinations that do not match the agency’s records. These Employer Correction Notices have been commonly known as “no-match” letters.
Employee handbooks are an often neglected and underappreciated company document. Preparing, maintaining, and updating a handbook that reflects the policies of your company and your operations takes time and expertise. A well-written employee handbook can be an effective document to ensure compliance with applicable laws as they evolve and as new laws go into effect. An outdated handbook can be a liability.
Remember full-service gas stations? These days, we have self-service pumps. Remember cashiers at the grocery store? Now, most chains offer self-service checkout. Remember the DOL auditing your labor practices? Not so fast – they still do that. But now employers can take the “do-it-yourself” approach too!
While it is easy to see the convenience and time savings of self-service at the gas station and the supermarket, it is not quite so obvious when it comes to the DOL. But they just may be on to something. As we previously reported, last spring the Wage and Hour Division (WHD) of the Department of Labor (DOL) launched the pilot Payroll Audit Independent Determination (“PAID”) program. Due to its success, the PAID program has been extended for another six months.
OSHA (the Occupational Safety and Health Administration) issued its electronic injury reporting rule in May, 2016. When issued, OSHA had intended all employers (over time) to submit their injury and illness records (OSHA Form 300 log of work-related injuries and illnesses), OSHA Form 301 (injury and illness incident report), and OSHA 300A (annual summary of work-related injuries and illnesses by establishment)) via a “secure” electronic system. OSHA would then use this information to publicly shame employers who had high injury or illness rates. The initial electronic filing obligation was limited to employers with 250 or more employees and employers with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. The initial filing was limited to the OSHA Form 300A, with a filing due date of July 1, 2017; which was then later moved back to December 30, 2017.