In a September 29, 2023 Advisory Opinion issued to Citigroup Inc. ("Citi"), the Department of Labor ("DOL") addressed several key ERISA implications...

Congress in 2001 added section 402A to the Internal Revenue Code to allow 401(k) plans to include a "qualified Roth contribution program" pursuant to which participants could designate their elective deferrals...

The IRS announced earlier this month that it is extending its pilot program under which retirement plan sponsors are given 90 days' notice...

Following up on the SECURE Act and other recent plan amendment extensions in Notice 2022-33, the IRS has issued Notice 2022-45 (Sept. 27, 2022) to extend the amendment deadlines for the remaining provisions...

On April 11, 2025, the Centers for Medicare & Medicaid Services ("CMS") published a Request for Information ("RFI") requesting the public provide feedback...

On May 21, 2025, the Centers for Medicare & Medicaid Services ("CMS") announced its intent "to crush[] fraud, waste, and abuse across all federal...

Earlier this month, the Department of Labor proposed a significant prohibited transaction exemption that would allow a plan sponsor's captive insurer to reinsure pension annuity risks.

On July 26, 2021, the IRS released Notice 2021-46 (the "Notice"), which provides new guidance on the 100% COBRA premium subsidies (the "Subsidies") and the related tax credit under...

On October 25, 2021, the Department of Labor ("DOL") issued Field Assistance Bulletin 2021-02 announcing...

The Setting Every Community Up for Retirement Enhancement Act of 2019 (Pub. L. 116-94, Division O, the "SECURE Act") ...

As employers using a pre-approved plan document are aware, a plan restatement must be adopted by the end of the two-year window following the 6-year remedial amendment period cycle.

IRS Notice 2022-33 provides extensions to the amendment deadlines for certain provisions of the Setting Every Community Up for Retirement Enhancement Act of 2019 ("SECURE Act")...

A recent IRS letter ruling provides helpful clarification on the interaction of in-service distributions to active employees (Code section 401(a)(36)) and the requirement that Code...

We've rounded up our latest resources into one place so that you don't have to! In case you missed any of our updates from last month, read on.

The SEC Staff has issued guidance clarifying how pooled employer plans (PEPs) should be treated under federal securities law, particularly addressing registration exemptions and removing barriers to PEP...

Groom principals Katie Bjornstad Amin and Michael Kreps were featured in Tax Notes' coverage of an International Foundation of Employee Benefit Plans ("IFEBP") webcast.

Federal agencies have issued new guidance addressing HIPAA wellness program rules amid ongoing litigation over tobacco premium surcharges. The guidance clarifies enforcement positions on retroactive reimbursement requirements and disclosure obligations for reasonable alternative standards in health-contingent wellness programs.

In welcome news for plan sponsors and other fiduciaries considering lifetime income solutions for their defined contribution ("DC") plans...

Today, the U.S. Department of Labor ("DOL") published a set of three direct final rules ("DFRs") in the Federal Register.

The IRS has updated its guidance on educational assistance programs under Code section 127, clarifying key timing requirements for expense reimbursements and student loan payments. These changes address long-standing questions about when employers can provide tax-free educational benefits and how the recent One Big Beautiful Bill Act affects annual contribution limits.