ABA Joint Committee on Employee Benefits gets answers from federal agencies on issues of interest to employee benefits' practitioners - and passes them on to you

Do the Circular 230 regulations apply to routine plan disclosure documents such as summary plan descriptions and S-8 prospectuses? If a foreign broad-based, funded, pension plan "generally corresponds" to a U.S. qualified plan, can the plan "roll over" into an IRA in the U.S.? These were just two of the dozens of questions asked of (and answered by) Internal Revenue Service and Treasury officials at the Section of Taxation meeting held in May of this year.

Each year, the ABA Joint Committee on Employee Benefits meets with officials of several federal agencies to discuss issues of interest to employee benefits practitioners. The informal question and answer period features questions from ABA members with responses from government representatives (who are speaking for themselves – their answers do not reflect government policy).

In addition to the IRS and Treasury, the Joint Committee met with officials from the Pension Benefit Guaranty Corporation, the Equal Employment Opportunity Commission, the Centers for Medicare and Medicaid Services, the Department of Health and Human Services and the Department of Labor.

Questions posed to the Centers for Medicare and Medicaid Services included ones on how the Center might respond to several situations involving the final HIPAA enforcement rule. Among the topics covered in the meeting with the Pension Benefit Guaranty Corporation were standard terminations, participant notices, ERISA section 4062(e) and 4063, valuation and guaranteed benefits.

The questions and answers from 2006 and previous year's meetings are available here on the Joint Committee's on Employee Benefits' Web site. The agencies receive the questions in advance, and agency personnel may review the answers given by departmental personnel before they're posted. The Web site contains transcripts of the issues discussed going back to the year 2000.

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