"If adopting any of the [health or dependent care FSA] relief offered by the Act, plan sponsors should consider taking steps to limit their financial exposure, including limiting the number of mid-year election changes that will be permitted and prohibiting reductions in pre-tax FSA elections or carryovers of unused contributions or balances that would result in underfunding of reimbursements that have already been made.... [Retirement plan] sponsors must begin to track hours worked by LTPTEs for plan years beginning in 2021 and retain that information in future years so they can determine whether plan eligibility is met under this provision for any plan years starting after December 31, 2023.... Plan sponsors should be aware that they will be inviting a potentially significant recordkeeping burden if they decide to amend their 401(k) plans to provide employer contributions to LTPTEs and subject those contributions to a vesting schedule."

MORE >>