The Washington Report

August 7, 2024

Note to Subscribers

While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.

Legislative

Congress Adjourned for August Recess
Congress has adjourned for its August recess. The House and Senate are scheduled to reconvene after the Labor Day holiday.

Health

CMS Releases Preliminary 2025 Medicare Part D Bid Information and Announces Premium Stabilization Demonstration
On July 29, 2024, the Centers for Medicare & Medicaid Services (CMS) released preliminary technical Medicare Part D bid information for contract year 2025, to help Part D plan sponsors finalize their Part D and Medicare Advantage offerings and prepare for Medicare Open Enrollment. For 2025, the base beneficiary premium is expected to increase by $2.08 for people with Medicare Part D. Additionally, CMS is announcing a voluntary demonstration to support implementation of the redesigned Part D benefit and improve stability and address variation for individuals with Medicare Part D in 2025

The news release is available here.

A Fact Sheet is available here.

Retirement

IRS Publishes Final Regulations on Plan-Specific Substitute Mortality Tables for Determining Present Value
On July 31, 2024, the Internal Revenue Service (IRS) published final regulations that update the requirements that a plan sponsor of a single-employer defined benefit plan must meet to obtain IRS approval to use mortality tables specific to the plan in calculating present value for minimum funding purposes (as a substitute for the generally applicable mortality tables). These regulations affect participants in, and beneficiaries of, certain retirement plans and employers maintaining those plans. The regulations became effective on July 31, 2024, and apply for plan years beginning on or after January 1, 2025.

The final regulations are available here.

IRS Releases Revenue Procedure for Requesting Approval of Plan-Specific Substitute Mortality Tables
On July 31, 2024, the IRS released Revenue Procedure 2024-32, which establishes the procedure by which the sponsor of a defined benefit plan that is subject to the funding requirements of Section 430 of the Internal Revenue Code may request approval from the IRS for the use of plan-specific substitute mortality tables in accordance with Section 430(h)(3)(C) and Section1.430(h)(3)-2 of the Treasury regulations. This Revenue Procedure updates the procedures set forth in Revenue Procedures 2017-55, 2017-43 IRB 373, and reflects the amendments to Section 1.430(h)(3)-2 that were published in the Federal Register on July 31, 2024. Additionally, in accordance with Section 1.430(h)(3)-2(c)(6)(ii)(E), Revenue Procedure 2024-32 also specifies the date by which the use of a previously approved substitute mortality table must be terminated in conjunction with the replacement of the generally applicable mortality tables specified in Section 430(h)(3)(A) and Section1.430(h)(3)-1.

IRS Revenue Procedure 2024-32 is available here.

Aon Publications

Now Available: Legal Consulting & Compliance Quarterly Update
The Retirement Legal Consulting & Compliance practice is pleased to present its Quarterly Update of recent legal developments for the third quarter of 2024. In this issue you will find the following articles:

DC Recordkeeping Searches in Today’s Environment
Post-Chevron and Its Meaning for Plan Sponsors and Fiduciaries
New $7,000 Cashout Limit Presents Opportunity
When Disaster Strikes: Retirement Plan Relief
Wanted: Your Retirement Plan Data to Build DOL Lost and Found Database
New Fiduciary Investment Advice Rule: What Does It Mean for Plan Sponsors?
Plan Administrator Support: Helping Plan Sponsors Focus on What Is Important
Quarterly Roundup of Other New Developments
Recent Publications

The third quarter 2024 issue of the Retirement Legal Consulting & Compliance Aon Quarterly Update is available here.