The Internal Revenue Service has developed a benefit plan review schedule that could affect the calendars of insurers, benefit plan advisors and employers for decades to come.[@@]
The IRS has published the schedule in Revenue Procedure 2005-66, which deals with the system it will use to issue the rulings and “determination letters” that help plan sponsors and administrators get IRS approval for plan changes.
Under the new system, the IRS will review changes proposed for individually designed plans every 5 years and plans for “pre-approved plans,” which are officially called “volume submitter plans” and “master and prototype plans” every 6 years, according to the text of the revenue procedure.
The IRS will use employers’ employer identification numbers, or EINs, to determine when they should submit routine requests for rulings and determination letters.
The IRS will issue annual lists of changes in rules and regulations to help plan sponsors and administrators decide what changes to include in plan updates.
When new pre-approved plans file for approval outside of the usual submission periods for plans with their EINs, the IRS will use the cumulative list of changes that would have applied if the plans were being reviewed “on cycle” during the most recently expired submission periods that would have applied to those plans if the plans were established plans, the IRS says.
The revenue procedure is on the Web at http://www.irs.gov/pub/irs-drop/rp-05-66.pdf