For more information on the Council's comment letter program, contact Jan Jacobson, senior counsel, retirement policy, or Kathryn Wilber, senior counsel, health policy, at (202) 289-6700.
Note: Letters are also available on the applicable issue pages.
- Council Letter to PBGC Urging Review of Early Warning Program
- As part of its ongoing defense of the defined benefit pension plan system, the Council sent a letter to the Pension Benefit Guaranty Corporation (PBGC) on April 24, urging a thorough review of the agency's Early Warning Program.
- Group Letter to OMB Regarding EEOC Proposed Revisions to EEO-1
- The Council was also one of 27 employer organizations to sign on to a similar group letter to OMB, urging the agency to review and reject the EEOC's revisions to the annual Employer Information Report (EEO–1) disclosure requirement.
- Letter to IRS on ongoing rulemaking with respect to hybrid retirement plans
- The Council offered constructive recommendations to the U.S. Treasury Department and Internal Revenue Service (IRS) in a February 21 letter (cosigned by the Coalition to Preserve the Defined Benefit System) addressing ongoing rulemaking with respect to hybrid retirement plans.
- Council Letter to DOL/EBSA Regarding Proposed Regulations on State/Local Retirement Plans
- The Council appreciates the opportunity to provide comments on the Department of Labor’s proposed rule that would extend the new safe harbor for state-run mandatory IRA programs for private-sector employees to similar programs that are established by certain populous cities and counties meeting the proposal’s definition of a “qualified political subdivision”.
- Council Letter to EEOC Regarding Proposed Changes to EEO-1
- In April 1 written comments, The Council urged the Equal Employment Opportunity Commission (EEOC) to withdraw and reconsider its proposed changes to the Employer Information Report (EEO–1), used to collect demographic information about employees.
- Council Letter to DOL Requesting Extension on Paid Leave NPRM
- In a March 10 letter to the U.S. Department of Labor (DOL), the Council asked the agency to extend the comment period for a proposed rule that will require federal contractors and their subcontractors provide employees with a certain amount of paid leave.
- Council Letter to EEOC Regarding Proposed GINA Title II Regulations
- In a January 28 letter to the U.S. Equal Employment Opportunity Commission (EEOC) regarding its proposed regulations governing employer wellness programs under Title II of the Genetic Information Nondiscrimination Act (GINA), the Council once again emphasized the importance of consistent federal policy that promotes the health of Americans and is aligned across multiple agencies and Congress.
- Group Letter to CMS Opposing Rate Cuts to Medicare Advantage Plans
- In written comments to the U.S. Department of Health and Human Services (HHS) Centers for Medicare and Medicaid Services (CMS), the Council and 11 other employer groups expressed concern with further cuts to the Medicare Advantage (MA) program.
- Council Letter to IRS Regarding State-Run Retirement Plans and ERISA Prohibited Transactions
- On behalf of the American Benefits Council (the “Council”), I am writing to seek clarification on whether the prohibited transaction excise tax regime described in Internal Revenue Code Section 4975 could apply to states that sponsor payroll deduction IRA arrangements for private sector employees, even where such arrangements are exempt from ERISA.
- Council Letter to IRS/OMB on Changes to Form 5500 Series
- This letter is submitted on behalf of the American Benefits Council (the Council) regarding the proposed changes to the Form 5500 series for the 2015 plan year, including proposed changes to the Form 5500-SUP described in the Notice and Request for Comment published in the Federal Register on December 23, 2014, and the changes reflected in the draft Form 5500-EZ.
- Council Letter to CMS on Request for Information Regarding HPID Requirements
- In July 28 written comments to the Centers for Medicare and Medicaid Services (CMS) of the U.S. Department of Health and Human Services (HHS), the Council urged the agency to eliminate the Health Plan Identifier (HPID) requirement in HIPAA administrative transactions. CMS requested input on the HPID rule, after having delayed enforcement of the requirement in October 2014.
- Council Letter to DOL/EBSA Proposed Regulations on Definition of the Term 'Fiduciary'
- The Council submitted comments on July 21 to the U.S. Department of Labor (DOL) on the proposed regulations redefining the term “fiduciary.” In the comments, the Council identified a number of issues of concern to plan sponsors and participants that are raised by the proposal, as well as potential issues that could arise. Our comment letter also provided several recommendations to ensure certainty and reduce liability for employers.
- Council/SPARK Institute Letter to NTIS Regarding Proposed Regulations on Certification Program for Access to the Death Master File
- In March 30 written comments to the National Technical Information Service (NTIS) of the U.S. Department of Commerce, the Council, along with the SPARK Institute, expressed concerns with the proposed regulations on a proposed certification program to provide access to the Death Master File (DMF). The letter suggested clarifications and changes that would continue to protect confidential DMF information from abuse while ensuring that retirement plan administrators are able to access DMF information for legitimate fraud prevention and business purposes.