Alden J. Bianchi

Alden J. Bianchi

Mintz Levin

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The Affordable Care Act—Countdown to Compliance for Employers, Week 2: Explaining the Look-Back Measurement Method to Employees

Many applicable large employers—i.e., employers that are subject to the Affordable Care Act’s (ACA) employer shared responsibility rules—have a pretty good sense of what these rules are, how they work, and what they plan to...more

12/17/2014 - Affordable Care Act ERISA Full-Time Employees Health Insurance Look-Back Measurement Period Shared Responsibility Rule

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 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 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 36: Hacking the Affordable Care Act’s $100/Day Penalties for...

Particularly with the issuance of final regulations under the Affordable Care Act’s employer shared responsibility rules, employers have been concerned—justifiably—with the pay-or-play penalties. ...more

4/22/2014 - Affordable Care Act COBRA Compliance Employee Benefits Employer Mandates Healthcare HIPAA Pay or Play Shared Responsibility Rule

The Affordable Care Act—Countdown to Compliance for Employers, Week 39: Common Law Employees and Offers of Coverage on Behalf of...

Distinguishing employees who are full-time from those who are not takes up a good deal of real estate in final regulations published in the Federal Register on February 12 implementing the Act’s employer shared responsibility...more

4/1/2014 - Affordable Care Act Employee Benefits Employer Mandates Full-Time Employees Healthcare Pay or Play Shared Responsibility Rule

The Affordable Care Act—Countdown to Compliance for Employers, Week 43: Coordinating the 3-Month Delay under Employer Shared...

So much attention has been paid to the issuance of the final employer shared responsibility regulations that some might have missed the news that final regulations were recently issued under another of the Affordable Care...more

3/4/2014 - Affordable Care Act Compliance Employee Benefits Employer Group Health Plans Employer Mandates Healthcare Healthcare Reform Pay or Play Shared Responsibility Rule

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 44: The Top 10 Changes Made by the Final Treasury Regulations...

In last week’s post on the topic of the recently issued final regulations under the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules, we suggested that the final regulations broke little new...more

2/25/2014 - Affordable Care Act Delays Employee Benefits Employer Mandates Healthcare Healthcare Reform Pay or Play Shared Responsibility Rule

The Affordable Care Act—Countdown to Compliance for Employers, Week 45: Focus on the Transition Rules under Final Treasury/IRS...

The Treasury Department and the IRS last week issued long-awaited final rules implementing the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules. Originally slated to take effect beginning...more

2/19/2014 - Affordable Care Act Delays Employee Benefits Employer Mandates Healthcare Pay or Play Shared Responsibility Rule

The Affordable Care Act—Countdown to Compliance for Employers, Week 48: Obamacare Dodges Another Bullet

A recent Federal Court decision turned back a potentially debilitating challenge to the Affordable Care Act’s rules governing premium subsidies. The decision, Halbig v. Sebelius, has consequences for large employers, i.e.,...more

1/28/2014 - Affordable Care Act Health Insurance Exchanges Healthcare Healthcare Reform Pay or Play Shared Responsibility Rule

Cafeteria Plans, the Affordable Care Act, and Continued Compliance with the Massachusetts Free-Rider Surcharge Requirement—New...

Established as a part of the comprehensive 2006 Massachusetts health care reform law, the Massachusetts Health Insurance Connector (a/k/a the “Connector”) served as a model for the American Health Benefit Exchanges that are a...more

8/2/2013 - Affordable Care Act Deadlines Delays Employee Benefits Employer Mandates Health Insurance Exchanges Healthcare HHS Pay or Play Shared Responsibility Rule

It’s Official: IRS Issues Guidance Affirming One-Year Delay in the Affordable Care Act Employer Mandate and Related Reporting...

On July 9, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....more

7/15/2013 - Affordable Care Act Deadlines Delays Employer Mandates Healthcare IRS Pay or Play Shared Responsibility Rule U.S. Treasury

Obama Administration Delays Enforcement of the ACA Employer Shared Responsibility Rule to 2015

In a move that took many by surprise, the Obama Administration on July 3 announced a one-year delay (to January 1, 2015 from January 1, 2014) in the enforcement of the employer mandate under the Patient Protection and...more

7/11/2013 - Affordable Care Act Deadlines Delays Employer Mandates Full-Time Employees Healthcare Pay or Play Shared Responsibility Rule U.S. Treasury

Obama Administration Announces a One-Year Delay in the Enforcement of the Affordable Care Act's Employer Shared Responsibility...

In a surprise announcement posted Tuesday to the White’s House website, the Obama Administration announced a one-year delay (to January 1, 2105) in the enforcement of the employer shared responsibility rules enacted into law...more

7/5/2013 - Affordable Care Act Deadlines Delays Employer Mandates Healthcare Pay or Play Shared Responsibility Rule Tax Penalties U.S. Treasury

IRS/Treasury Issue Employer Shared Responsibly Proposed Regulations

Beginning in 2014, the Patient Protection and Affordable Care Act (Act) requires “applicable large employers” (i.e., employers with 50 or more full-time equivalent employees) to either offer group health insurance coverage to...more

1/17/2013 - Affordable Care Act Employer Group Health Plans Healthcare Pay or Play Shared Responsibility Rule

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