Human Resources

The Washington Report

October 27, 2021

Note to Subscribers

The Washington Report will not be published on November 3, 2021. Look for your next Aon Washington Report on Wednesday, November 10, 2021.



IRS Issues Two FAQs on Rehired Retirees and In-Service Distributions
On October 22, 2021, the Internal Revenue Service (IRS) added two questions to previously posted frequently asked questions (FAQs) intended to assist employers that are experiencing COVID-19-related labor shortages. The new FAQs apply to pension plans and provide guidance for employers that either rehire retirees or retain current employees who have attained age 59 ½ or the plan’s normal retirement age. The new FAQs provide: 1) the tax status of a pension plan will not be jeopardized if a retiree is rehired as long as the individual had a bona fide retirement; and 2) participants can commence benefits while employed provided they have attained age 59 ½.

A news release is available here.

The new FAQs are available here.

PBGC Posts 2022 Maximum Monthly Guarantee Limits
On October 20, 2021, the Pension Benefit Guaranty Corporation (PBGC) posted a table showing the 2022 guarantee limits for various ages and payment forms. As a result of the indexing rules provided by law, the maximum guarantee limits for single-employer plans that fail in 2022 will be 2.82% higher than the limits that applied for 2021. The guarantee limits for multiemployer plans are not indexed and have not changed.

The table with the 2022 Maximum Monthly Guarantee Limits is available here.

Other HR/Employment


EEOC Issues Updated COVID-19 Technical Assistance About Religious Objections to Vaccine Requirements
On October 25, 2021, the Equal Employment Opportunity Commission (EEOC) posted updated and expanded technical assistance related to COVID-19, addressing questions about religious objections to employer COVID-19 vaccine requirements and how they interact with federal equal employment opportunity laws. The expanded technical assistance provides new information about how Title VII of the Civil Rights Act applies when an applicant or employee requests an exception from an employer’s COVID-19 vaccination requirement that conflicts with their sincerely held religious beliefs, practices, or observances. Title VII prohibits employment discrimination based on race, color, religion, sex, and national origin.

Updates to the technical assistance are summarized below:

  • Employees and applicants must inform their employers if they seek an exception to an employer’s COVID-19 vaccine requirement due to a sincerely held religious belief, practice, or observance.
  • Title VII requires employers to consider requests for religious accommodations but does not protect social, political, or economic views, or personal preferences of employees who seek exceptions to a COVID-19 vaccination requirement.
  • Employers that demonstrate “undue hardship” are not required to accommodate an employee’s request for a religious accommodation.

(Please refer to the complete guidance for all updates and details.)

For a more detailed Aon bulletin, please see EEOC Issues Additional Guidance for Employers on Religious Objections to Employer COVID-19 Vaccine Mandates, in the Publications section of the newsletter.

The news release is available here.

The updated guidance is available here.

Aon Publications


EEOC Issues Additional Guidance for Employers on Religious Objections to Employer COVID-19 Vaccine Mandates
The Equal Employment Opportunity Commission (EEOC) on October 25, 2021, issued updated guidance for employers on COVID-19 vaccine employer mandates and applicability of various equal employment opportunity laws, including religious objections under Title VII of the Civil Rights Act of 1964.

The Aon bulletin, which provides an overview of the key updates to the guidance, is available here.

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