Comment Letters

The Church Alliance writes and distributes comment letters, memoranda and other materials regarding laws and regulations that impact church retirement and health benefit plans.

Health Care

The Church Alliance submitted a comment letter to the Department of Health and Human Services (HHS) on August 13, 2019 in support of its proposed rule on Nondiscrimination in Health and Health Education Programs and Activities.  The proposed rule...

The Church Alliance submitted a letter to the Department of Health and Human Services (“HHS”) on March 27, 2019 in response to a Request for Information published on February 25, 2019 regarding grandfathered group health plans and grandfathered health...

The Church Alliance submitted comments to the Internal Revenue Service regarding the Summary of Benefits and Coverage (“SBC”) that health plans are required to prepare and distribute under the Affordable Care Act.  The scope of the comments was...

The Church Alliance filed a comment letter on the Notice of Proposed Rulemaking published by the Departments of Treasury, Labor, and Health and Human Services (“Departments”) regarding a proposal to allow integrating health reimbursement arrangements...

The Church Alliance submitted a comment in response to the proposed rule (the “Proposed Rule”) regarding short-term, limited-duration insurance (“STLDI”), issued jointly by the Department of the Treasury, the Department of Labor, and the Department of...

The Church Alliance submitted comment in response to the interim final rules (the “Rules”) regarding religious exemptions and accommodations for coverage of certain preventive services under the Patient Protection and Affordable Care Act (“ACA”)...

The Church Alliance submitted comment in response to a request for information (RFI) from the Center for Faith-Based and Neighborhood Partnerships, Department of Health and Human Services (HHS), on ways in which HHS can remove barriers to the...

The Church Alliance submitted comment in response to a request for information (RFI) from the Department of the Treasury on ways in which Treasury regulations could be eliminated or modified to reduce burdens. The Church Alliance took the opportunity...

The Church Alliance submitted comment in response to a request for information (RFI) from the Centers for Medicare & Medicaid Services, Department of Health and Human Services (HHS), on ways in which HHS could reduce regulatory burdens, promote...

The Church Alliance submitted comment in response to a request for information (RFI) from the Department of the Treasury, the Department of Labor and the Department of Health and Human Services (together, the “Departments”) regarding the Affordable...

The Church Alliance submitted comment in response to a proposed rule issued by the Department of Health and Human Services that addresses Section 1557 of the Affordable Care Act (ACA). Section 1557 prohibits discrimination on the basis of race, color...

From the Church Alliance to the Internal Revenue Service (IRS), in response to Notice 2015-52, which solicited additional comments in preparation for proposed regulations to be issued concerning the “Cadillac Tax” on high cost employer-sponsored...

From the Church Alliance to the Internal Revenue Service (IRS), in response to Notice 2015-16, which solicited comments in preparation for proposed regulations to be issued concerning the “Cadillac Tax” on high cost employer-sponsored health coverage...

The Church Alliance submitted comment in response to the interim final rule (IFR) regarding coverage of preventive services under the Affordable Care Act (“ACA”) issued jointly by the Internal Revenue Service, the Department of Labor and the...

From the Church Alliance to the Internal Revenue Service (IRS), Department of Labor, and Department of Health and Human Services commenting on Notice 2013-54 : Application of Market Reform and other Provisions of the Affordable Care Act to HRAs,...

From the Church Alliance to the Internal Revenue Service commenting on how the proposed rule for information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans (Section 6056 Reporting) under the...

The Church Alliance submitted comment in response to the notice of proposed rulemaking regarding preventive services (“NPRM”) issued jointly by the Internal Revenue Service, the Department of Labor and the Department of Health and Human Services (HHS...

From the Church Alliance to the Internal Revenue Service commenting on how the proposed rule for shared responsibility for employers regarding health care (the “Pay or Play Rule”) under the Patient Protection and Affordable Care Act (PPACA) should be...

From the Church Alliance to the Department of Health and Human Services commenting on how the Final Regulations regarding preventive services under the Affordable Care Act (ACA) should be revised so that churches and/or church-related employers in...

From the Church Alliance to the IRS explaining the difficulties for church health plans under Notice 2011-28, the proposed rule for reporting the value of employer health coverage on employees’ Forms W-2.

Retirement/Tax

The Church Alliance submitted a comment letter to the Internal Revenue Service on  June 7, 2019 in response to a Request for Comments on the 2019-2020 Priority Guidance Plan (contained in Notice 2019-30).  We advised the Service that our top two...

The Church Alliance submitted comments to the Internal Revenue Service (“IRS”) on IRS Notice 2018-99.  This Notice contains interim guidance on a new tax on transportation fringe benefits provided by tax-exempt organizations.  The Church Alliance...

The Church Alliance submitted a letter to the Internal Revenue Service in response to a request for comment on a section of the Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) relating to church plans. Among other things, the letter...

The Church Alliance submitted a comment letter to the Internal Revenue Service concerning the Tax Cuts and Jobs Act provision, Code Section 512(a)(6), changing the calculation of the unrelated business income tax (UBIT). The comment letter suggests...

The Church Alliance submitted a comment letter supplementing the comment letter submitted on August 20, 2018 to the Treasury Department and Internal Revenue Service concerning the definition of a “church plan” in section 414(e) of the Internal Revenue...

The Church Alliance submitted a comment letter to the Treasury Department and Internal Revenue Service (“Service”) concerning the definition of a “church plan” in section 414(e) of the Internal Revenue Code.  Included in the comment letter are...

The Church Alliance submitted a comment letter to the Treasury Department and Internal Revenue Service ("Service"), addressing the recent enactment of a new tax on parking and other transportation fringe benefits provided by tax-exempt organizations...

The Church Alliance submitted a comment to the Department of Treasury and the Internal Revenue Service, asking for transition relief related to (e.g., a delay in implementation) two new tax provisions in 2017’s tax reform law. Section 512(a)(6) of the...

The Church Alliance submitted comments to the Department of the Treasury (“Treasury”) in response to a request for recommendations on Treasury Regulations that may be eliminated, modified, or streamlined to reduce burdens. The comment letter explains...

The Church Alliance submitted comments to the Senate Finance Committee (SFC) in response to a request for recommendations on comprehensive tax reform. The comment letter explains to the SFC how several longstanding provisions of the tax code have been...

On August 3, the Church Alliance submitted a comment letter to the Internal Revenue Service and Treasury Department, addressing the recent enactment of the Church Plan Clarification Act (“CPCA”, which was enacted as part of the “PATH” Act of 2015) and...

Financial Services

The Church Alliance submitted a comment to the Securities and Exchange Commission (“SEC”) regarding possible revisions of regulations promulgated by the SEC on business conduct standards for security-based swap dealers and major security-based swap...

On July 22, the Church Alliance submitted a comment letter to the SEC on a Dodd-Frank-related proposal. By way of background, Section 956 of the Dodd-Frank Act requires that the banking regulators, SEC, and CFTC, prohibit certain incentive-based...