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As announced in our December 2015 alert, the Consolidated Appropriations Act was passed to permanently create parity between the mass transit/commuter benefit (Transit Expenses) limit and the qualified parking benefit so that both limits under Code 132 are increased to $255 per month effective January 1, 2016. However, the Act also provided a retroactive increase to the 2015 Transit Expenses from $130 per month to $250 to match the monthly benefit maximum for qualified parking expenses, which left employers with many questions as to how to implement the increase for 2015.

Companies need to consider the makeup of their employee populations as they develop best practices on their benefits communications. Your communication model needs to be part of a long-term strategy that can seamlessly move from one method to another. Different generations receive information in different ways. You need a plan that can reach these groups and provide the information that they need to know.

The guidance is provided in a question-and-answer format, with comments requested on several issues that the IRS plans to address in forthcoming rules. The Notice supplements previous guidance on several issues, including Health Reimbursement Arrangements (HRAs) and Employer Payment Plans, providing additional clarification and, in some cases, transition relief or grace periods for compliance.

All applicable large employersthose with 50 or more full-time employees, including full-time equivalents (FTEs) are required to report whether minimum value, affordable coverage was offered to any employees who were full-time for at least one month during the calendar year. And all employers sponsoring a self-funded medical plan are required to report on all individuals covered under the plan, even those who are not full-time employees. The employer will report the required information by using Forms 1094 and 1095 (B or C). Employers who must provide 250 or more Forms 1095 are required to file electronically.