Simplification Award Rules

2024 Employee Benefits Simplification Award

The American College of Employee Benefits Counsel (College) hereby invites academics, practitioners, and any other individuals interested in the employee benefits system to submit proposals to simplify employee benefits law. The winning submission (or submissions) will:

  • Receive a $10,000 prize that will be awarded at the College’s black-tie dinner and induction ceremony to be held at the National Portrait Gallery in Washington, DC on September 14, 2024.
  • Have the opportunity to participate in a webinar focused on the submission that will be hosted by the College and likely other organizations.
  • If there are multiple winners, each winning submission will receive an equal portion of the $10,000 prize, and each will have the opportunity to participate in webinar. One webinar may include all winning submissions, or there may be multiple webinars.

In addition, if the author(s) wish, the judges of the ACEBC® Simplification Award Committee commit to work with the author(s) to find a suitable venue for publication of the winning submission and any other submissions awarded an honorable mention by the judges).

Format of Submissions

  • ABSTRACT: Each submission should begin with a brief abstract describing the proposed change and its benefits.
  • BLUE BOOK FORMAT: Thereafter, the submission should follow the format used in the Joint Committee on Taxation’s “Blue Book” explanation of enacted tax legislation (i.e., current law, reasons for change, description of proposal).
  • DETAILED ANALYSIS OF PROPOSAL: In addition, each proposal should include a final section of “Detailed Analysis” that:
    • Thoroughly details the simplification that will result from the proposal and the benefits of that simplification. The more those benefits can be quantified, the better. In terms of cost reductions, the cost impact on all the stakeholders in the employee benefits system (regulators, employers, participants, third-party providers, etc.) should be considered, but no formal cost-benefit analysis is required. In addition to reducing costs, other simplification benefits, such as increasing the availability or level of benefits, making compliance with the benefit rules more user-friendly or easier to navigate, or increasing participants’, employers’, and the public’s understanding and appreciation of benefits should be described.
    • Explains how the proposal either enhances or, at the least, has no material adverse impact on employee/participant rights.
    • Identifies and analyzes other ancillary advantages or benefits and any policy tradeoffs.
  • STATUTORY/REGULATORY CHANGES: Each submission should identify the specific statutory or regulatory provision(s) that would need to be amended to implement the proposal. Submissions that include detailed proposed statutory or regulatory language changes are strongly encouraged but are not mandatory (as long as the nature and extent of the required changes are clear).
  • LENGTH OF SUBMISSIONS: Submitters are encouraged to limit the length of submissions to 15 pages (not counting citations in footnotes or endnotes, or the statutory or regulatory changes).
  • TEMPLATE: The Simplification Award Template, available here, provides comprehensive guidance on the format of a submission. The template is the preferred and recommended method of submitting a simplification proposal to this competition. The template ensures that the submission considers all of the relevant criteria against which the proposal will be judged.

Criteria for Evaluation of Submissions

  • SIMPLIFICATION OF THE EMPLOYEE BENEFITS SYSTEM: A primary criterion for judging submissions will be the extent to which the simplification suggested would be expected to improve the effectiveness/efficiency of the employee benefits system, specifically plans governed by ERISA or the tax code.
  • ORIGINALITY: The degree of originality will be a criterion in evaluating submissions. A submission will be judged by the extent to which it makes a significant new contribution to the debate on the subject, i.e., through new analysis, new data, or otherwise persuasively making the case for the changes proposed.

    In judging the proposal’s originality, the existence of similar proposals that have been part of the public discussion (for example, those offered by the author(s), scholars or interested organizations) will not disqualify the proposal from consideration. However, the submission should identify any earlier paper or other material and credit the source or sources from which the proposed simplification was derived. Similarly, a proposal that is based on, or adapts ideas or material considered previously by, for example, Congress or an agency, will be eligible for consideration, except that proposals that are substantially similar to legislation that is currently pending before Congress would not be considered original. In addition, the author should state in the submission if, as of the time of submission, the author is aware of any substantially similar legislation pending currently in Congress or recently introduced but not adopted by Congress.
  • LIKELIHOOD OF ENACTMENT AND IMPLEMENTATION: Another important criterion for evaluating submissions will be the ease or difficulty of having the suggested changes adopted and carried out. This includes consideration of the reaction of all stakeholders, particularly participant advocates and the plan sponsor community and, as appropriate, potential revenue implications of the suggested simplification (although formal revenue estimates are not expected).
  • PAPERS SUBMITTED FOR PUBLICATION: ACEBC® Simplification Award submissions that are based on a paper submitted for publication in law reviews or other law school journals or periodicals, or for scholarly seminars or symposia are eligible for the award, provided that the College receives any consents necessary to publish or republish the submission. In addition, past publication of a simplification proposal by the author (or others) will not disqualify the proposal provided the originality standards discussed above are satisfied.

Process for Submitting Proposals

  • DEADLINE: Submissions for the 2024 ACEBC® Simplification Award must be received no later than Midnight, Eastern Time on June 1, 2024. It is anticipated that the winner of the award will be notified by August 1, 2024, or shortly thereafter.
  • PROCESS FOR MAKING SUBMISSION: Participants are strongly encouraged to use the Simplification Award Application Template in preparing their submissions. Papers must be submitted as email attachments to and should be submitted as Word documents. No information identifying the author or the author’s professional affiliation should be included in the text, the footnotes, or the filename. The author’s name, professional affiliation, email address, mailing address, and telephone number should be provided in the cover email message.

Evaluation of Submissions

  • SIMPLIFICATION AWARD COMMITTEE: The winning submission will be selected by the Award Committee, which is composed of ACEBC® Members selected by the ACEBC® Board of Governors (BOG). The Award Committee’s selection will be based on the factors identified above and on any other factors that the Award Committee (in its sole discretion) deems relevant. The Award Committee’s selection of a winner will be subject to the approval of the BOG as further discussed below.
  • PROCESS: To the maximum extent possible, submissions will be evaluated by the Award Committee on a blind basis (that is, the Award Committee will not know the identity of the submitter). The Award Committee will select the winning submission based upon a majority vote of its members. However, the Committee will not recommend any winning submission to the BOG if any Award Committee member believes that suggested policy change would reduce protections or rights of employees and/or their beneficiaries or is intended to implement major policy changes beyond simplification. Similarly, if four or more members of the BOG object to the Award Committee’s choice because they believe it would detract from employee rights or make major policy changes beyond simplification, then the BOG would veto the Award Committee’s choice of award recipient. The BOG may request the identity of the Award Committee’s choice of award recipient.
  • DETERMINATIONS ARE FINAL: The determinations of the BOG will be final. No award will be granted for a year if the BOG determines (after consideration of the comments and recommendations of the Award Committee) that none of the proposals submitted fully satisfy the criteria set forth in the rules, as elaborated in the FAQs and any other guidance posted on the College website.

Other Matters

    • Any individual or individuals with an interest in employee benefits is eligible, except that members of the Award Committee and current Members of the BOG (and their family members) cannot receive any portion of the award.
    • Informal groups of individuals are welcome to collaborate on a submission. A group must identify all individuals collaborating on a submission and designate one individual as the lead contact. The award will be paid to that individual, unless otherwise specified by the group.
    • A simplification proposal will not be considered by the Award Committee or the BOG if the person submitting or collaborating in the submission of a proposal (or a firm or organization to which such a person belongs or by which he or she is employed) has been engaged by a client to make a submission with respect to, or otherwise to influence the development or outcome of, the specific subject matter addressed by the proposal. This disqualification rule does not apply solely because a person working on or submitting a proposal has clients that might be affected by the principles addressed by the proposal.