Alden J. Bianchi

Alden J. Bianchi

Mintz Levin

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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 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 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 IRC IRS Minimum Value Plans Reference Pricing Shared Responsibility Rule

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 IRC IRS Look-Back Measurement Period

The Affordable Care Act—Countdown to Compliance for Employers, Week 16: So What, Exactly, is an “Offer of Coverage”?

Whether an employer makes the requisite offer of group health plan coverage is critical to the application of the Affordable Care Act’s employer shared responsibility rules as reflected in final implementing regulations...more

9/9/2014 - Affordable Care Act Deadlines Employer Mandates ERISA Full-Time Employees Health Insurance Healthcare Healthcare Reform IRS

The Affordable Care Act—Countdown to Compliance for Employers, Week 17: Cherry Bomb in the Gold Fish Pond, or Third-Party Staffing...

With two seemingly simple and straightforward definitions in the final regulations implementing the Affordable Care Act’s pay-or-play rules—i.e., definitions of “employer” and “employee”— the Treasury Department and IRS have...more

9/4/2014 - Affordable Care Act Compliance Healthcare IRS U.S. Treasury W-2

The Affordable Care Act—Countdown to Compliance for Employers, Week 18: Emerging Strategies to Reduce or Eliminate Exposure for...

The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...more

8/26/2014 - Affordable Care Act Employer Liability Issues Final Rules Full-Time Employees IRC IRS Pay or Play

The Affordable Care Act—Countdown to Compliance for Employers, Week 20: 9.5% ? 9.56% (And Why It Matters to Applicable Large...

While employers sometimes view the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules in isolation, they don’t operate that way. Instead, they exist side-by-side with other provisions of the Act. In...more

8/12/2014 - Affordable Care Act Compliance Employee Benefits Employer Mandates Healthcare IRS Pay or Play Subsidies Tax Credits

The Affordable Care Act—Countdown to Compliance for Employers, Week 22: Charting the Future of the Premium Subsidies (and Employer...

On July 22, 2014, two federal appellate courts issued conflicting decisions, within hours of each other, regarding the IRS final rule published on May 23, 2012 (the “IRS Rule”), intended to implement the exchange-related tax...more

7/28/2014 - Affordable Care Act Chevron Deference Employer Mandates Halbig v Burwell Health Insurance Health Insurance Exchanges Healthcare Reform IRS King v Burwell Subsidies Tax Credits

Charting the Future of Premium Subsidies under the Affordable Care Act: Halbig v. Burwell and King v. Burwell

On July 22, 2014, two federal appellate courts issued conflicting decisions, within hours of each other, regarding the IRS final rule published on May 23, 2012 (the “IRS Rule”), intended to implement the exchange-related tax...more

7/25/2014 - Affordable Care Act Halbig v Burwell Healthcare IRS King v Burwell Subsidies Tax Credits

The Affordable Care Act—Countdown to Compliance for Employers, Week 24: Can Offers of Group Health Plan Coverage Under Code...

The Employer Shared Responsibility provisions of the Affordable Care Act (“ACA”) generally require “applicable large employers” (i.e., employers who employed at least 50 full-time and full-time equivalent employees on...more

7/16/2014 - Affordable Care Act Contractors DOL Employee Benefits Employer Contributions Employer Group Health Plans Employer Mandates Federal Contractors IRS Service Contract Act Subcontractors U.S. Treasury Wage and Hour

The Affordable Care Act—Countdown to Compliance for Employers, Week 26: Fitting a Round Peg (the Public Health Service Act 90-day...

The Departments of the Treasury/IRS, Labor and Health and Human Services (the “Departments”) recently issued a final regulation under the 90-day waiting period limitation, which is included among the Affordable Care Act’s...more

6/30/2014 - Affordable Care Act DOL Employer Mandates ERISA Healthcare Healthcare Reform HHS IRC IRS PHSA U.S. Treasury

The Affordable Care Act—Countdown to Compliance for Employers, Week 28: The Logic, Calculus, and Limits of “Skinny” Plans

It was just over a year ago that the Wall Street Journal published an article entitled, “Employers Eye Bare-Bones Health Plans Under New Law,” which highlighted a compliance strategy to minimize employer exposure for...more

6/17/2014 - Affordable Care Act Employee Benefits Employer Group Health Plans Employer Mandates Healthcare HIPAA IRS Skinny Plan

The Affordable Care Act—Countdown to Compliance for Employers, Week 31: ERISA Section 510 and Limiting Employee Hours

In last week’s post, we examined the appropriateness of capping the annual hours of new “variable hour employees” as a way to limit exposure under the Affordable Care Act’s employer shared responsibility rules. (These rules...more

5/27/2014 - Affordable Care Act Compliance Employee Benefits Employer Mandates ERISA Healthcare Healthcare Reform IRS Shared Responsibility Rule

The Affordable Care Act—Countdown to Compliance for Employers, Week 37: Stalking the Elusive “Variable Hour Employee”

For “applicable large employers” (i.e., generally, those employers who employed an average of at least 50 full-time employees on business days during the preceding calendar year), determining which employees are “full-time”...more

4/15/2014 - Affordable Care Act Full-Time Employees IRS Safe Harbors Variable Hour Employees

The Top 10 Changes Made to the 2012 Proposed Rule Under the Affordable Care Act’s Employer Shared Responsibility Rules by Recently...

The Treasury Department and Internal Revenue Service recently issued final regulations implementing the employer shared responsibility provisions of the Affordable Care Act. For “applicable large employers” — i.e., those with...more

2/25/2014 - Affordable Care Act Delays Employee Benefits Employer Mandates Healthcare Healthcare Reform IRS Shared Responsibility Rule U.S. Treasury

The Affordable Care Act—Countdown to Compliance for Employers, Week 46: Looking Ahead to the Group Health Plan Non-Discrimination...

A January 18th New York Times article (Rules for Equal Coverage by Employers Remain Elusive Under Health Law) reported on the progress, or lack thereof, of the adoption of group health plan non-discrimination regulations...more

2/11/2014 - Affordable Care Act Discrimination Healthcare Healthcare Reform IRS

The Affordable Care Act—Countdown to Compliance for Employers, Week 45½: Treasury/IRS Issue Long-Awaited Final Regulations under...

Breaking with long standing tradition—i.e., issuing important rules on a Friday before a holiday weekend, or (failing that) any Friday (hence the reference to Week 45½ in this post)—the Treasury Department and the IRS today...more

2/11/2014 - Affordable Care Act Employer Mandates Healthcare Healthcare Reform IRS Pay or Play U.S. Treasury

The Affordable Care Act—Countdown to Compliance for Employers, Week 49: Waiting for the Final Code Section 4980H Regulations

So where are they? Final regulations implementing the Affordable Care Act’s rules governing shared responsibility of employers were widely expected to have “dropped” before the beginning, or perhaps during the first...more

1/22/2014 - Affordable Care Act Compliance Employer Mandates Healthcare Healthcare Reform IRS U.S. Treasury

The Affordable Care Act—Countdown to Compliance for Employers, Week 51: Speculating about Code Section 4980H Transitional Relief

(Note: This is the first installment of a series of entries that Alden will be posting each week for the next 51 weeks as he counts down to the January 1st, 2015 ACA pay-or-play deadline). ...more

1/7/2014 - Affordable Care Act Compliance Healthcare Healthcare Reform IRS Pay or Play Transition Relief

The New, New (EPCRS Voluntary Correction) Thing: 457(b) Plans

The IRS’s Employee Plans Compliance Resolution System (or “EPCRS”) permits corrections, both voluntary and on audit, of a broad range of “qualification failures” — i.e., violations of sometimes arcane and complex tax rules —...more

12/31/2013 - 457(b) Plans Benefit Plan Sponsors Deferred Compensation EPCRS IRS Qualified Benefit Plans Qualified Retirement Plans Tax Qualified Retirement Plans

Treasury Department/IRS Issue Proposed Rules on Employer Reporting of Health Insurance Coverage Under the Affordable Care Act

In addition to imposing substantive requirements on health insurance issuers in the group and individual markets and employer-sponsored group health plans, the Patient Protection and Affordable Care Act (Act) imposes three...more

10/22/2013 - Affordable Care Act Health Insurance Health Insurance Exchanges Healthcare IRS Reporting Requirements U.S. Treasury

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