Publication
SW Benefits Update – COVID-19 and Cafeteria Plans: To Amend or Not to Amend?
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By Allison B. Bans On May 12, the IRS issued Notice 2020-29 “COVID-19 Guidance Under Section 125 Cafeteria Plans and Related to High Deductible Health Plans” and Notice 2020-33 “Section 125 Cafeteria Plans – Modification of Permissive Carryover Rule for Health Flexible Spending Arrangements and Clarification Regarding Reimbursements of Premiums by Individual Coverage Health Reimbursement Arrangements.” As explained in more detail below, Notice 2020-29 provides increased flexibility for cafeteria plans in response to the COVID-19 pandemic and Notice 2020-33 increases the health flexible spending arrangement (“Health FSA”) carryover limit and clarifies the ability of a health plan to reimburse individual insurance policy premium expenses incurred prior to the beginning of the plan year. |
About Snell & Wilmer
Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 16 locations throughout the United States and in Mexico, including Los Angeles, Orange County and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
