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Miscellaneous News & Regulations


Notice 2009-27 // 3/31/2009

This notice provides guidance relating to section 3001 of the American Recovery and Reinvestment Act of 2009 (ARRA), Public Law 111-5, enacted February 17, 2009, relating to premium assistance for COBRA continuation coverage.

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Title III of ARRA // 2/17/2009

Premium assistance of COBRA benefits

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Defense of Marriage Act of 1996 // 2/5/2009



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Children's Health Insurance Program Reauthorization Act of 2009 // 2/4/2009

Children's Health Insurance Program Reauthorization Act of 2009

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Debit cards used to reimburse participants in self-insured medical reimbursement // 2/4/2009

This notice provides further guidance on the use of debit cards, credit cards, and stored value cards (cards) to reimburse participants in self-insured medical reimbursement plans, such as health flexible spending arrangements (health FSAs) and health reimbursement arrangements (HRAs).

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Debit Card Use - Amounts Received Under Accident and Health Plans // 2/4/2009

This notice provides transition relief with respect to the use of debit cards for medical expense reimbursements at certain merchants with non-health care related merchant category codes. It also addresses the use of debit cards for medical expense reimbursements at stores with the Drug Stores and Pharmacies merchant category code.

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Debit Cards - Amounts Received Under Accident and Health Plans - Revenue Ruling 2008-104 // 2/4/2009

This notice provides additional transition relief with respect to the use of debit cards for medical expense reimbursements at stores with the Drug Stores and Pharmacies merchant category code.

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New - IRS Debit Card Guidance // 7/13/2006

The IRS has issued its much anticipated follow up to its original electronic payment card guidance. Notice 2006-69 (the “Notice”) clarifies the parameters established in its original 2003 guidance (Notice 2003-43). In addition, the Notice clarifies and expands the substantiation requirements generally (whether a debit card is used or not). Plan sponsors and administrators should undertake a careful review of their current systems now, as many common industry practices may be adversely affected by the Notice. What follows are our very preliminary observations with regard to this Notice.

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IRS Notice 2005-86 - HSA Eligibility During a Cafeteria Plan Grace Period // 4/28/2006

Health Savings Account eligibility during a cafeteria plan grace period.

Download PDF: IRS Notice 2005-86 - HSA Eligibility During a Cafeteria Plan Grace Period.pdf