Affordable Care Act

IRS Issues New Draft Forms and Instructions for ACA-Required Reporting in 2016

MARY POWELL and ERIC SCHILLINGER, August 2015 — On August 7, 2015, the IRS issued new draft forms and instructions to be used by certain health-coverage providers and employers who are required by the Patient Protection and Affordable Care Act (the “ACA”) to report health coverage offered and provided in the prior calendar year on […]

Plan Year Changes for Group Health Plans for Year-End 2015 and 2016

TIFFANY N. SANTOS, August 2015 — As the end of the 2015 calendar plan year and the next open enrollment period for the 2016 calendar year group health plan fast approach, employers and other plan sponsors of self-insured health plans must implement and administer a number of changes to comply with the Affordable Care Act […]

Opt-Out Payments and Health Coverage Affordability Issues

MARY POWELL and ERIC SCHILLINGER, August 2015 — Beginning this year in 2015, the Patient Protection and Affordable Care Act’s Employer Shared Responsibility Provisions under Internal Revenue Code (“Code”) Section 4980H (often referred to as the “Employer Mandate” or the “Pay-or-Play Rules”) took effect, requiring an “applicable large employer” to either offer certain health coverage […]

New ACA Guidance on Requirement to Cover Preventive Health Services

TIFFANY N. SANTOS, July 2015 — On July 14, 2015, the Internal Revenue Service, Department of Labor and Department of Health and Human Services (the “Departments”) jointly finalized interim final regulations issued in July 2010 regarding the Affordable Care Act’s (“ACA”) requirement to cover certain preventive health services without cost-sharing by non-grandfathered plans. They also […]

ACA Compliance Remains “Business as Usual” for Employers Following King v. Burwell

TIFFANY N. SANTOS and MARSHAL HODA, July 2015 In its much-anticipated June 25, 2015 decision in King v. Burwell, the United States Supreme Court upheld nationwide federal health care subsidies under the Affordable Care Act (“ACA”). King affirmed that the premium tax credit under Section 36B of the Internal Revenue Code (the “Code”) is available […]

Plan Sponsors Gear Up for Required ACA Reporting of Coverage

ERIC J. SCHILLINGER, May 2015 — As mid-2015 is fast approaching, employers and plan sponsors that have not yet contemplated their reporting obligations under the Affordable Care Act may wish to consider starting now. In early 2016, insurers, plan sponsors of self-funded plans and employers with 50 or more full-time equivalent employees will need to […]

New Final ACA Rules Regarding Limited Wraparound Coverage as an Excepted Benefit

FREEMAN L. LEVINRAD, May 2015 — On March 18, 2015, the Department of Labor, the Department of the Treasury, and the Department of Health and Human Services (the “Departments”) jointly issued final rules (the “Final Rules”) amending proposed regulations previously issued under the Affordable Care Act (the “ACA”) regarding the inclusion of “limited wraparound coverage” […]

IRS Closes Minimum Value Loophole and Kills Skinny Plans for Employers Subject to Play or Pay Mandate

On November 4, 2014, the Internal Revenue Service (IRS) and the Department of Health and Human Services (HHS) issued Notice 2014-69, disapproving employers’ use of “skinny” health plans that limit coverage for inpatient hospitalization services and/or physician services for the purpose of meeting the minimum value requirement of Internal Revenue Code (the “Code”) section 4980H […]

New FAQs Issued on ACA’s Cost-Sharing Limitations for Plans Using Reference-Based Pricing

ERIC J. SCHILLINGER, October 2014 — On October 10, 2014, the Department of the Treasury, Department of Labor and Department of Health and Human Services (collectively the “Departments”) jointly issued FAQs Part XXI (“FAQs”). The FAQs address compliance with the annual cost-sharing limitations under the Patient Protection and Affordable Care Act (the “ACA”) for non-grandfathered […]

Amendments to Excepted Benefits Regarding Dental Plans, Vision Plans and EAPs Finalized

TIFFANY N. SANTOS, September 2014 On September 26, 2014, 1 the Department of the Treasury, Department of Labor and Department of Health and Human Services jointly finalized the amendments to the “excepted benefit” regulations regarding dental and vision plans and employee assistance programs (“EAPs”). While the amended regulations adopt the original proposed regulation language eliminating […]

New Mid-Year Section 125 Permitted Election Changes Help Facilitate ACA Marketplace Enrollment

TIFFANY N. SANTOS, September 2014 — On September 18, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-55, which allows an employee to revoke an election for employer-sponsored health plan coverage under a Section 125 cafeteria plan (but not a health flexible spending account (“FSA”)) on a prospective basis in the following circumstances: Following a […]

IRS Announces PCORI Fee Increase

JENNIFER TRUONG, September 2014 On September 18, 2014, the Internal Revenue Service (“IRS”) published Notice 2014-56, announcing that the adjusted “applicable dollar amount” for the Patient-Centered Outcomes Research Institute (“PCORI”) fee imposed by §§ 4375 and 4376 of the Internal Revenue Code will increase to $2.08 from $2.00 for policy and plan years ending on […]

IRS Issues Draft Forms for the Reporting of Coverage under the Affordable Care Act

TIFFANY N. SANTOS, July 2014 — On July 24, 2014, the Internal Revenue Service (“IRS”) released draft forms for review and comment implementing the reporting requirements under Sections 6055 and 6056 of the Internal Revenue Code (the “Code”) (Please see our May 2013 and March 2014 articles for detailed discussions of these reporting requirements). Section […]

Determination of Employer “Pay or Play” Assessment Under Affordable Care Act Cast into Doubt Following Recent Court Split

TIFFANY N. SANTOS, July 2014 — As employers prepare to comply with the Affordable Care Act’s employer shared responsibility provision (or “Pay or Play” requirement) under Section 4980H of the Internal Revenue Code (the “Code”), two recent conflicting Court of Appeals decisions regarding the availability of the premium tax credit to purchase Marketplace/Exchange coverage could […]

Final 90-Day Health Plan Waiting Period Rules Issued

SONYA M. GORDON, June 2014 — On June 25, 2014, the Internal Revenue Service, Department of Labor and Department of Health and Human Services (collectively, the “Departments”) published final rules addressing the maximum length of an employment-based orientation period (the “June 2014 Final Regulations”) that would be consistent with the 90-day waiting period limitation under […]

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