Health and Welfare Plans

EEOC’s Proposed Rule on GINA and Wellness Programs: Approving Spousal HRA Incentives and Clarifying Other Matters

JAHIZ NOEL AGARD, December 2015 — On October 30, 2015, the U.S. Equal Employment Opportunity Commission (EEOC) released proposed regulations on Title II of the Genetic Information Nondiscrimination Act (GINA) that reverse a prior position prohibiting wellness programs from requiring an employee to provide his genetic information (which includes information about a spouse or other […]

New IRS Proposed Regulations Defining Minimum Value for Employer Shared Responsibility Provisions

JENNIFER TRUONG, September 2015 — On September 1, 2015, the Internal Revenue Service (“IRS”) issued new proposed regulations on the determination of whether an employer-sponsored health plan provides “minimum value,” for purposes of the employer “offer of coverage requirement under Section 4980H of the Internal Revenue Code Under the proposed regulations and consistent with IRS […]

New Model COBRA Notices and a Hodgepodge of ACA Guidance

With Affordable Care Act (the “ACA”) compliance efforts in full swing, the agencies charged with enforcing the law have been steadily issuing guidance to help employers, plans and plan participants understand their obligations and rights, respectively. On May 2, 2014, the Department of Labor (“DOL”) published new FAQs addressing various ACA provisions, including the annual […]

IRS Announces 2015 HSA and HDHP Limits

On April 23, the Internal Revenue Service released Rev. Proc. 2014-30, which provides the following 2015 inflation-adjusted limits applicable to Health Savings Accounts (HSA) and High Deductible Health Plans (HDHP): 2015 HSA Maximum Contribution Limits Self-Only HDHP Coverage: $3,350 Family HDHP Coverage: $6,650 2015 HDHP Minimum Deductible Limits Self-Only HDHP Coverage: $1,300 Family HDHP Coverage: […]

Recent DOMA/Windsor Guidance Issued Regarding Cafeteria Plans, Flexible Spending Accounts and Health Savings Accounts

Following the U.S. Supreme Court’s decision that the Defense of Marriage Act’s (“DOMA”) restriction on marriage to opposite-sex spouses for purposes of federal law is unconstitutional, the IRS issued initial guidance on how the ruling affects employee benefit plans in Revenue Ruling 2013-17 [see United States v. Windsor, 133 S. Ct. 2675 (2013)] (see our […]

IRS Eases Use-It-or-Lose-It Rule by Announcing $500 Health FSA Carryover

BRIAN GILMORE, November 2013 — Plan sponsors and participants have reason to rejoice. The IRS has relaxed Code section 125’s rigid use-it-or-lose-it rule for health flexible spending accounts (“Health FSAs”) by allowing up to $500 of unused contributions to carry over into the following plan year. For plan sponsors, this will help address the administrative […]

Final Regulations for Compliance with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008

On November 8, 2013, the Departments of Labor, Health and Human Services (HHS) and the Treasury (the “Departments”) issued Final Rules implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”) and a set of Frequently Asked Questions as part of the series of FAQs implementing the Affordable […]

When Is It Too Late? The Supreme Court Will Hear Case on Statute of Limitations Contained in Employee Benefit Plan

The Supreme Court yet again has the opportunity to opine on whether the terms of an employee benefit plan are enforceable as written — this time in the context of a plan’s deadline for participants to bring a lawsuit on a denied benefit claim. On October 15, 2013, the nine justices will hear oral argument […]

IRS Issues Guidance Implementing the Health Insurance Coverage Information Reporting Requirements Under the Affordable Care Act

On September 5, 2013, the Internal Revenue Service (“IRS”) issued two sets of proposed regulations (Proposed Regulations Sections 1.6055-1 and 1.6055-2 and Proposed Regulations Sections 301.6011-9, 301.6056-1 and 301.6056-2) implementing the information reporting requirements under Internal Revenue Code Sections 6055 and 6056 added by the Patient Protection and Affordable Care Act (the “Act”). These reports […]

PAY OR PLAY RULES — DELAYED!

On July 9, 2013, the Internal Revenue Service issued Notice 2013-45 (“Notice”), which provides for transition relief until 2015 from information reporting requirements under Internal Revenue Code (“IRC”) sections 6055 and 6056. These sections require an employer to annually report to the IRS information regarding the health insurance that the employer offers (or does not […]

Final Regulations for Wellness Programs under Health Care Reform

On May 29, 2013, the Departments of Treasury, Labor and Health and Human Services (the “Departments”), released final regulations on incentives for nondiscriminatory wellness programs in group health plans (“Final Regulations”) as provided for under the Patient Protection and Affordable Care Act of 2010 (“PPACA”). The Final Regulations apply to both grandfathered and non-grandfathered group […]

New October 1, 2013 Employer Disclosure Deadline: DOL Issues PPACA Model Notice of Exchange (and Updated COBRA Model Election Notice)

On May 8, the Department of Labor (DOL) issued Technical Release 2013-02 providing guidance on the model Patient Protection and Affordable Care Act (PPACA) Notice of Exchange and the associated employer compliance obligations, as well as the DOL’s updated model COBRA election notice, which has been revised to address changes under PPACA. NOTICE OF EXCHANGE […]

IRS Issues Health Insurance Premium Tax Credit Regulations

The Internal Revenue Service (“IRS”) recently issued a series of final and proposed regulations relating to the health insurance premium tax credit. Enacted by the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 (“ACA”), the premium tax credit is set forth in Section 36B of the Internal […]

Additional Guidance on 90-day Waiting Period Limitation Issued

On March 19, 2012, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) issued proposed rules implementing the 90-day waiting period limitations under the Patient Protection and Affordable Care Act (“PPACA”). These 90-day waiting period limitations apply to insured as well as self-funded plans (regardless of grandfathered or non-grandfathered status). These proposed […]

Health Care Reform and the Health Insurance Market: Guaranteeing Better Access

On February 22, 2013, the Centers for Medicare & Medicaid Services (“CMS”) released final regulations on health insurance market reforms (“Final Regulations”) as provided for under the Patient Protection and Affordable Care Act of 2010 (the “ACA”). The Final Regulations apply to the health insurance markets for individuals and small groups for policy and plan […]

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