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… or after April 1, 2020, and before July 15, 2020. The guidance is consistent with previous IRS announcements that provided similar taxpayer relief in connection with the COVID-19 pandemic. The DOL subsequently issued Disaster Relief Notice 2020-01 which confirmed that Form M-1 filings ‒ for multiple employer welfare arrangements (MEWAs) ‒ also get extended filing relief for the same period as the IRS Form 5500.  The regular deadline for annual Form M-1 filings is March 1, with an automatic 60-day extension available if timely requested. Since that extended deadline falls within the relief window, timely extended 2019 …

… compensation arrangement (e.g., piece rate) or who received other types of payments (e.g., commissions or tips), might have a fluctuating average rate week to week, so the Departments have stated that an employer may calculate the correct average regular rate for these employees as follows: Compute the employee’s non-excludable remuneration for each full workweek during the six-month period. Notably, commissions and piece-rate pay counts towards this amount. Tips, however, count only to the extent that an employer applies them towards minimum wage obligations (i.e., the employer takes a tip credit). Overtime premiums …

… health plan expenses are determined separately for each plan. Then, for each plan, the employer should allocate expenses to the employees who participate in that plan. In the case of an employee who participates in more than one plan (e.g., a group health plan and a health flexible spending arrangement (HFSA), the allocated expenses of each plan in which the employee participates are aggregated for that employee. Fully insured plans. An eligible employer who sponsors a fully insured group health plan may use any reasonable method to determine and allocate the plan expenses, including: the COBRA applicable premium for …