Alden J. Bianchi

Alden J. Bianchi

Mintz Levin

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The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 14 of 24): Coding Form 1095-C, Part II for...

When reporting offers of coverage to full-time employees under the Affordable Care Act’s (ACA) employer shared responsibility rules, much of the detail appears in Part II of IRS Form 1095-C, Lines 14, 15 and 16. For the most...more

10/23/2015 - Affordable Care Act Employer Mandates Full-Time Employees Health Insurance Hiring & Firing IRS Minimum Value Plans New Hires Part-Time Employees Penalties Reporting Requirements Shared Responsibility Rule

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 13 of 24): Coding Form 1095-C, Part II for...

Compliance with the Affordable Care Act’s (ACA) employer shared responsibility rules requires that applicable large employers identify their full-time employees. A “full-time employee” for this purpose is an employee who...more

10/14/2015 - Affordable Care Act Disability Leave Employer Mandates Excise Tax Full-Time Employees Health Insurance IRS Large Employer Penalties Reporting Requirements Safe Harbors U.S. Treasury

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 12 of 24): Deconstructing Form 1095-C, Parts II...

This series is devoted principally to the reporting requirements imposed by Internal Revenue Code §§ 6055 and 6056 as added by §§ 1502 and 1514 of the Affordable Care Act (ACA), respectively. The former reports offers of...more

10/6/2015 - Affordable Care Act Employer Liability Issues Employer Mandates Health Insurance Individual Mandate IRS Minimum Essential Coverage Popular Reporting Requirements

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 9 of 24): Unraveling the Mystery of Indicator...

The Affordable Care Act’s reporting rules—which are set out in Internal Revenue Code §§ 6055 and 6056—solicit the information needed by the Internal Revenue Service to enforce the individual and employer shared responsibility...more

9/15/2015 - Affordable Care Act Employer Group Health Plans Employer Mandates Internal Revenue Code (IRC) IRS Large Employer Look-Back Measurement Period Minimum Essential Coverage Reporting Requirements Shared Responsibility Rule Subsidies

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 5 of 24): Reporting of Health Reimbursement...

As we reported last week, the IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C. These instructions are of interest to applicable large employers who must report their compliance with the Affordable Care...more

8/19/2015 - Affordable Care Act Employer Group Health Plans Employer Mandates Form 1094 Form 1095 Health Savings Accounts HRA IRS Large Employer Minimum Essential Coverage Reporting Requirements Section 6055 Shared Responsibility Rule Supplemental Insurance

The Affordable Care Act’s Reporting Requirements for Carriers and Employers: The Basics (Part 3 of 24)

Alden Bianchi, Chair of Mintz Levin’s Employee Benefits & Executive Compensation Practice, will provide a weekly installment on the complex reporting obligations outlined by the Affordable Care Act for health insurance...more

8/5/2015 - Affordable Care Act Employer Mandates Health Insurance Individual Mandate IRS Minimum Essential Coverage Reporting Requirements Shared Responsibility Rule Tax Penalties

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 1 of 24)

Alden Bianchi, Chair of the our Employee Benefits & Executive Compensation Practice, will provide a weekly installment on the complex reporting obligations outlined by the Affordable Care Act for health insurance carriers and...more

7/20/2015 - Affordable Care Act Compliance Corporate Counsel Employer Group Health Plans Employer Liability Issues Employer Mandates Exceptions Good Faith Health Insurance Individual Mandate IRS Minimum Essential Coverage Penalties Popular Reporting Requirements Self-Funded Health Plans

The Impact of King v. Burwell on “Applicable Large Employers”

Reports in the popular media portrayed King v. Burwell as a case involving premium tax subsidies used to purchase health insurance from public exchanges or marketplaces under the Affordable Care Act (ACA). According to an...more

7/7/2015 - Affordable Care Act Employer Mandates Health Insurance Health Insurance Exchanges IRS King v Burwell SCOTUS Shared Responsibility Rule State Health Insurance Exchanges Subsidies Tax Credits

ACA Countdown to Compliance - 52 Week Series For Employers

In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more

2/25/2015 - ADA Affordable Care Act Cafeteria Plans EEOC Employer Group Health Plans Employer Mandates ERISA Full-Time Employees Health Insurance Honeywell International HSA Minimum Value Plans Pay or Play Self-Insured Health Plans Shared Responsibility Rule Wellness Programs

The Affordable Care Act—Countdown to Compliance for Employers, Week 0: Final Thoughts and Acknowledgements

The Affordable Care Act is the single most important piece of Federal social legislation in more than a generation. While there was and is broad agreement on the law’s principal goals—to expand medical coverage, increase the...more

12/30/2014 - Affordable Care Act Employer Mandates Healthcare Reform

The Affordable Care Act—Countdown to Compliance for Employers, Week 1: Going Live with the Affordable Care Act’s Employer Shared...

Regulations implementing the Affordable Care Act’s (ACA) employer shared responsibility rules including the substantive “pay-or-play” rules and the accompanying reporting rules were adopted in February. Regulations...more

12/23/2014 - Affordable Care Act Employer Liability Issues Employer Mandates IRS Shared Responsibility Rule

The Affordable Care Act—Countdown to Compliance for Employers, Week 4: EEOC v. Honeywell and the Future of Wellness Programs

While my entries have focused principally on the employer shared responsibility rules of the Affordable Care Act (ACA), every once in a while an item comes along that nevertheless grabs my attention. The treatment of wellness...more

12/2/2014 - ADA Affordable Care Act Disability Discrimination EEOC Employer Liability Issues Employer Mandates Honeywell International Wellness Programs

The Affordable Care Act—Countdown to Compliance for Employers, Week 5: Health and Human Services (HHS) Wastes No Time Issuing...

Over the last couple of months, we have followed and reported on a particular ACA compliance strategy under which an employer subject to the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules...more

11/24/2014 - Affordable Care Act Employer Group Health Plans Employer Mandates Health Insurance HHS Internal Revenue Code (IRC) Minimum Essential Coverage Minimum Value Plans Pay or Play

The Affordable Care Act—Countdown to Compliance for Employers, Week 6: Labor and Treasury Departments Play Whack-a-Mole with...

Last year, the Department of Labor and the Treasury Department/IRS (Departments) issued guidance on the application of certain of the Affordable Care Act’s insurance market reforms to health reimbursement arrangements (HRAs),...more

11/18/2014 - Affordable Care Act Employer Group Health Plans Employer Mandates Flexible Spending Accounts Health Insurance HRA IRS U.S. Treasury

The Affordable Care Act—Countdown to Compliance for Employers, Week 7: IRS Puts the Kibosh on Health Plans that Fail to Cover...

In a previous post, we described an Affordable Care Act compliance strategy—referred to commercially as a “minimum value plan” or “MVP”—that involves an offer of group health plan coverage that, while similar in most respects...more

11/11/2014 - Affordable Care Act Employer Group Health Plans Employer Mandates Health Insurance HHS Hospitals Minimum Value Plans Pay or Play Physicians U.S. Treasury

The Affordable Care Act—Countdown to Compliance for Employers, Week 9: Misunderstanding “Offer[s] of Coverage on Behalf of Another...

Applicable large employers faced with the prospect of complying with the Affordable Care Act’s employer shared responsibility rules must grapple with and understand what is means to make an offer of minimum essential coverage...more

10/28/2014 - Affordable Care Act Employer Mandates Full-Time Employees Minimum Essential Coverage Shared Responsibility Rule Staffing Agencies

The Affordable Care Act—Countdown to Compliance for Employers, Week 10: What’s an Employer to Do (with Marketplace Notices)?

Under the Affordable Care Act’s employer shared responsibility rules, applicable large employers (those with 50 or more full-time and full-time equivalent employees on business days during the preceding calendar year) incur...more

10/22/2014 - Affordable Care Act Employer Mandates Health Insurance Exchanges Healthcare Marketplace Notice

The Affordable Care Act—Countdown to Compliance for Employers, Week 11: Rethinking ACA Compliance Strategies Involving Reference...

Under the Affordable Care Act’s rules governing employer shared responsibility—which are codified in Internal Revenue Code § 4980H—where an applicable large employer makes an offer of group health plan coverage that is both...more

10/15/2014 - Affordable Care Act Employer Mandates Full-Time Employees HHS Internal Revenue Code (IRC) IRS Minimum Value Plans Shared Responsibility Rule

The Affordable Care Act—Countdown to Compliance for Employers, Week 12: The Treatment of Unpaid Leaves of Absence Under the...

Final regulations implementing the Affordable Care Act’s employer shared responsibility rules furnish employers with two alternative methods—the monthly measurement method and the look-back measurement method—for identifying...more

10/6/2014 - Affordable Care Act Employer Mandates Internal Revenue Code (IRC) Look-Back Measurement Period Unpaid Leave

The Affordable Care Act—Countdown to Compliance for Employers, Week 13: IRS Notice 2014-49 Offers Useful Guidance on Changes in...

For purposes of complying with the Affordable Care Act’s employer shared responsibility rules (which are codified in Internal Revenue Code § 4980H), employers must identify their “full-time employees.” Final regulations...more

9/29/2014 - Affordable Care Act Employer Mandates Full-Time Employees Internal Revenue Code (IRC) IRS Look-Back Measurement Period

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