Funding Relief

[Effen]

I think I printed a copy of the Senate version before Obama signed it. Towards the end, there was a section titled Section 315 Transition Rule for Certifications of Plan Status. Section (b)(2) of this section said if you wanted to change a past certification as a result of the new law you had to do so within 75 days after the enactment of the Act.

I printed the CCH version after it was signed, which was labeled Senate version as approved by the House and signed by the President; however, this section seems to be gone.

Did they delete the 75 day requirement before it was signed?

[Guest Matthew Gouaux]

You're looking at Section 315 of the May version of HR 4213, the Tax Extenders bill. The multiemployer provisions of the funding relief bill signed by the President (HR 3962) was taken from a prior version of the Tax Extenders bill that was passed by the Senate in March, and not the more recent version of the same bill passed in the House in May, which includes Section 315. My understanding is that for some reason Congress scrapped several months of work that went into improving the multiemployer funding relief provisions of the Tax Extenders bill. Here's a link to the bill the President signed into law as Public Law No. 111-192: http://frwebgate.access.gpo.gov/cgi-bin/ge...3962enr.txt.pdf.

[Effen]

Thank you. So I guess that means we have absolutely no guidance on how to handle a potential status change as a result of the new law? This is just insanity!

[david rigby]

... we have absolutely no guidance ... This is just insanity!

Surprise!