Alden J. Bianchi

Alden J. Bianchi

Mintz Levin

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ACA Reporting on Forms 1094-C and 1095-C, AIRTN500 Error Messages, and Incorrect and Missing Taxpayer Identification Numbers...

Employer-sponsored group health plans and health insurance issuers (or carriers) are subject to information reporting requirements under the Affordable Care Act (ACA), including the obligation to report taxpayer...more

9/22/2016 - Affordable Care Act Covered Employees Form 1094 Form 1095 IRS Minimum Essential Coverage Proposed Regulation Solicitation Taxpayer Identification Number

Hospital and Fixed Indemnity Policies; Excepted Benefits; Supplemental Coverage under Recently Proposed Treasury Regulations; and...

We reported in a recent post on proposed regulations dealing with, among other things, the treatment of hospital indemnity or other fixed indemnity insurance products in the group market. This post takes a closer look at the...more

8/27/2016 - Affordable Care Act Employer Group Health Plans ERISA Health and Welfare Plans Health Insurance HHS Hospitals Indemnity Minimum Essential Coverage NAIC Supplemental Insurance

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

This post concludes our half-year series of posts focusing on the Affordable Care Act’s reporting requirements. These requirements are challenging in the extreme. Carriers and employers, and their vendors, service providers...more

1/4/2016 - Affordable Care Act Applicable Large Employers (ALE) Filing Deadlines IRS Minimum Essential Coverage Reporting Requirements

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 21 of 24): Reporting for “MEC” Plans

It took a while, but most employers and their advisors have finally gotten the hang of the Affordable Care Act’s employer shared responsibility rules. That is, they understand generally that: 1. “Applicable Large...more

12/14/2015 - Affordable Care Act Employer Group Health Plans IRS Minimum Essential Coverage Reporting Requirements Shared Responsibility Rule

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

11/3/2015 - Affordable Care Act Employer Group Health Plans Final Rules Form 1094 Form 1095 HRA IRS Medicaid Medicare Medicare Advantage Medicare Part B Minimum Essential Coverage Reporting Requirements State Medicaid Programs Supplemental Insurance TRICARE 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 11 of 24): Reporting 2015 Coverage of “MV-Lite”...

In Notice 2014-69, the Treasury Department and the IRS clarified that a group health plan that fails to provide substantial coverage for in-patient hospitalization and physician services will not be treated as providing...more

9/30/2015 - Affordable Care Act Amended Regulation Employer Group Health Plans Employer Liability Issues Health Insurance HHS Hospitals IRS Minimum Essential Coverage Minimum Value Plans Physicians Proposed Regulation Tax Credits U.S. Treasury

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

Beware of Stop-Loss Coverage Gaps When Choosing a Self-Funded Major Medical Plan

The Affordable Care Act requires applicable large employers to make broad-based offers of group health insurance coverage to substantially all their full-time employees or face potential tax penalties. (The term “applicable...more

2/25/2015 - Affordable Care Act Employer Group Health Plans Health Insurance Minimum Essential Coverage Self-Funded Health Plans Shared Responsibility Rule

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 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

ACA Update: Who Will Staffing Firms Have to Cover Starting Jan. 1, 2015?

The Obama administration's July 2013 announcement, delaying enforcement of the employer mandate under the Affordable Care Act by one year, has affected not only when employees must be offered health insurance coverage but...more

12/18/2013 - Affordable Care Act Compliance Health Insurance Exchanges Healthcare Minimum Essential Coverage Staffing Agencies

A Primer on “Low-Cost” Group Health Plans

A May 10 Wall Street Journal article, “Employers Eye Bare-Bones Health Plans Under New Law” (see the associated video on WSJ Live), highlighted a compliance strategy to minimize employer exposure for assessable payments under...more

6/19/2013 - Affordable Care Act Employer Group Health Plans ERISA Healthcare Minimum Essential Coverage Public Health Service Act

Temporary and Contract Workers: Who Is a “Variable Hour” Employee under the Affordable Care Act?

The Affordable Care Act’s employer shared responsibility rules will require large employers (50 or more full-time and full-time equivalent employees) to make an offer of minimum essential coverage to at least 95% of their...more

6/10/2013 - Affordable Care Act Excise Tax Independent Contractors Minimum Essential Coverage Pay or Play Temporary Employees Variable Hour Employees Wages

IRS, Treasury Department Issue Proposed Rules Governing Minimum Value, Affordability, and Wellness Programs

A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more

5/17/2013 - Affordable Care Act Employer Group Health Plans Essential Health Benefits IRS Minimum Essential Coverage Minimum Value Plans Proposed Regulation Safe Harbors Wellness Programs

On the Manifold Meanings of "Affordability" According to the Patient Protection and Affordable Care Act

The core policy goals of the Patient Protection and Affordable Care Act (the “Act”)—on which there is near universal consensus—are threefold: expand health care coverage; increase the quality of medical outcomes, and reduce...more

4/12/2013 - Affordable Care Act Employer Group Health Plans Healthcare Minimum Essential Coverage Pay or Play Tax Credits

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