Human Resources

The Washington Report

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September 25, 2019



PBGC Announces New 4062(e) Form Series
On September 18, 2019, the Pension Benefit Guaranty Corporation (PBGC) released new forms relating to reporting for a substantial cessation of operations event under ERISA Section 4062(e). An event occurs when there is a permanent cessation of operations at a facility which results in a workforce reduction of more than a 15% in the total number of eligible employees eligible to participate in any employee pension plan (i.e. any defined benefit plan or defined contribution plan) maintained by members of the controlled group. Reporting is waived for small plans and plans which are well-funded. If reporting is not waived, these forms can be used to report the cessation, elect to make additional contributions, notify when a contribution is made or no longer applies, and notify of any failure to make additional contributions.

Information on the 4062(e) Form Series is available here.

Other HR/Employment


DOL Releases Final Rule on Overtime Pay
On September 24, 2019, the Department of Labor (DOL) released a final rule on overtime pay. The final rule updates the earnings thresholds necessary to exempt executive, administrative, and professional employees from the Fair Labor Standards Act’s minimum wage and overtime pay requirements, and allows employers to count a portion of certain bonuses/commissions towards meeting the salary level. According to the news release, the new thresholds account for growth in employee earnings since the thresholds were last updated in 2004. In the final rule the DOL is:


  • Raising the "standard salary level" from the currently enforced level of $455 to $684 per week (equivalent to $35,568 per year for a full-year worker);
  • Raising the total annual compensation level for "highly compensated” employees from the currently-enforced level of $100,000 to $107,432 per year;
  • Allowing employers to use nondiscretionary bonuses and incentive payments (including commissions) that are paid at least annually to satisfy up to 10% of the standard salary level, in recognition of evolving pay practices; and
  • Revising the special salary levels for workers in U.S. territories and in the motion picture industry.


The final rule will become effective on January 1, 2020.

The final rule is available here.

The news release is available here.

A fact sheet is available here.

Frequently asked questions about the final rule are available here.

Additional information about the final rule is available here.

Aon Publications


Departments Release FAQs on Mental Health Parity Rules
The Departments of Labor, Health and Human Services, and Treasury (the Departments) issued a set of Frequently Asked Questions (FAQs) on September 5, 2019, along with a final model disclosure request form, under the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), as amended. The FAQs focus on the nonquantitative treatment limitation and disclosure requirements under the MHPAEA, addressing:


  • Plan Limitations or Exclusions Related to Experimental or Investigative Treatment;
  • Dosage Limits for Prescription Medications;
  • Step Therapy;
  • Eating Disorders; and
  • General Exclusion of All Benefits for a Particular Condition or Disorder.


The Aon bulletin, which discusses the FAQs and provides more information on the model disclosure request form, is available here.

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