In light of the rapidly changing coronavirus (COVID-19) situation, Troutman Sanders and Pepper Hamilton have postponed the effective date of their previously announced merger until July 1, 2020. The new firm – Troutman Pepper – will feature 1,100+ attorneys across 23 U.S. offices. Read more.
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. View the reference guide here.
If you have any questions or require assistance, please contact any member of the Pepper Hamilton or Troutman Sanders Employee Benefits and Executive Compensation practice groups or the COVID-19 Response Team. We are here to help you in any way that we can. This alert reflects guidance as of May 13, 2020.
The material in this publication was created as of the date set forth above and is based on laws, court decisions, administrative rulings and congressional materials that existed at that time, and should not be construed as legal advice or legal opinions on specific facts. The information in this publication is not intended to create, and the transmission and receipt of it does not constitute, a lawyer-client relationship.