Elizabeth L. Loh

Be Prepared to Respond to IRS Employer Shared Responsibility Payment Assessments

ELIZABETH LOH, December 27, 2017   Although it is the holiday season and people’s thoughts have turned to vacation with family, eggnog, and gift giving — employers have something slightly less festive to contemplate. The Internal Revenue Service (IRS) has started to send out letters to employers regarding potential Employer Shared Responsibility Payments (ESRP) (one of […]

Qualified Small Employer Health Reimbursement Arrangements Available for Small Employers

ELIZABETH LOH and MARY POWELL, December 2016     On December 13, 2016, the 21st Century Cures Act (“Act”) was enacted. The Act contains a special holiday gift for small employers. The Act allows a small employer to offer “Qualified Small Employer Health Reimbursement Arrangements” (“QSEHRA”) that may be used by eligible employees for the […]

Be Prepared for Phase Two of the HIPAA Audit Program

ELIZABETH LOH, April 2016 – Introduction On March 21, 2016, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) launched Phase Two of its Health Insurance Portability and Accountability Act (“HIPAA”) Audit Program. In this phase of the HIPAA Audit Program, the OCR intends to audit a wide variety of covered […]

COBRA Compliance and the Health Flexible Spending Account Carryover

ELIZABETH L. LOH, October  2014 — In Internal Revenue Service (“IRS”) Notice 2013-71, the IRS issued guidance allowing Health Flexible Spending Accounts (“Health FSAs”) to offer carryovers of unused balances of up to $500 remaining at the end of a plan year to be used for qualified medical expenses in a subsequent plan year (See […]