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… will not cause an HDHP to fail to be an HDHP, nor would it render someone ineligible to contribute to an HSA. For example an otherwise eligible individual with coverage under an HDHP, who also received coverage beginning February 15, 2020, for telehealth and other remote care services under an arrangement that is not an HDHP before satisfying the HDHP deductible, will not be disqualified from contributing to an HSA during 2020. Conclusion These continue to be trying times, but the IRS remains committed to helping employers and employees who are grappling with difficult plan coverage and administrative matters during …

… 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 …