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IRS Adjusted ACA Fee Amounts for the 2017 Policy or Plan Years

The Patient-Centered Outcomes Research Institute (PCORI) fee was established under the Affordable Care Act (ACA) to advance comparative clinical effectiveness research. The PCORI fee is assessed on issuers of health insurance...more

EEOC Issues Guidance on Employer Provided Wellness Programs

The Equal Employment Opportunity Commission (EEOC) has released long-awaited proposed guidance (the proposed rule) relating to employer wellness programs. The proposed rule amends regulations implementing Title I of the...more

Employer Shared Responsibility Payments and Reporting Requirements Under the Affordable Care Act: Code Sections 6055 and 6056

Employer Shared Responsibility Penalties - There are two types of employer shared responsibility payments, also known as pay or play penalties, under the Affordable Care Act (ACA). The first penalty under Internal...more

Individual Responsibility under the ACA

Effective 2014, if a taxpayer is not covered under minimum essential coverage for one or more months, then, unless an exemption applies, the taxpayer is liable for the individual shared responsibility payment on his return. ...more

Upcoming Health and Welfare Plan Requirements Checklist for Employers

As the mid-way point of 2014 approaches, employers should actively turn their attention to several upcoming compliance obligations for the health and welfare benefit plans they sponsor. Below is a checklist of upcoming...more

U.S. Appeals Courts Issue Conflicting Decisions on Whether ACA Permits Tax Subsidies of Health Care Coverage Purchased Through...

On July 22, 2014, three-judge panels of the U.S. Courts of Appeals for the District of Columbia and Fourth Circuits issued conflicting decisions regarding whether the Affordable Care Act (ACA) permits federal tax credits for...more

Closely Held Corporations Can Be Exempt from ACA Contraception Provisions Based on Religious Objections

The Patient Protection and Affordable Care Act (ACA) requires certain employers to cover women’s preventive health care under their nongrandfathered group health plans at no cost to employees. The U.S. Department of Health...more

IRS Rules Captive Reinsurance Arrangement Involving Retiree Medical Benefits Qualifies as Insurance for Federal Tax Purposes

On May 18, 2014, the Internal Revenue Service (IRS) ruled that an employer’s wholly owned captive insurance subsidiary could reinsure the employer’s retiree medical benefit risks and still qualify as insurance for federal tax...more

IRS Releases 2015 Amounts for HSAs, HDHPs

On April 23, 2014, the U.S. Treasury Department and Internal Revenue Service (IRS) released Revenue Procedure 2014-30, which lists the 2015 indexed amounts, adjusted for inflation, for health savings accounts and...more

Final Regulations Issued Regarding Employer Reporting Requirements Under ACA

Recently issued final regulations on the employer reporting requirements under the Affordable Care Act (ACA) clarify and streamline the process for reporting information relating to the provision of minimum essential coverage...more

Final Regulations Issued Regarding Employer Shared Responsibility Under the ACA

Recently issued final regulations on the employer pay-or-play rules under the Affordable Care Act (ACA) clarify the requirement that employers provide health coverage to full-time employees and their dependents, or pay a...more

Proposed Regulations Expand the Definition of Excepted Benefits

Recently issued proposed regulations would expand the categories of excepted benefits under the Employee Retirement Income Security Act of 1974 (ERISA), the Internal Revenue Code (the Code) and the Public Health Service Act. ...more

New Health Savings Account Contribution and Distribution Forms Issued by IRS

The Internal Revenue Service recently issued its 2014 versions of the Health Savings Account contribution and distribution forms and instructions. The forms released, and a link to those forms are below...more

New FAQs Released Regarding Implementation of the Affordable Care Act and Mental Health Parity

Recent guidance clarifies important issues under the Affordable Care Act, including mental health parity requirements; coverage of preventive care services; cost-sharing requirements; and out-of-pocket maximums, wellness...more

Final Regulations on the Mental Health Parity and Addiction Equity Act of 2008 and New Affordable Care Act FAQs

Final regulations have been issued implementing the Mental Health Parity and Addiction Equity Act of 2008 (Act). The Act generally requires group health plans (or health insurance coverage offered in connection with such a...more

Modification of “Use It or Lose It” Rule for Health Flexible Spending Arrangements

The Internal Revenue Service recently issued new guidance modifying the “use it or lose it” rule applicable to health flexible spending arrangements (FSAs) to allow carryover of certain unused health FSA amounts into the next...more

New Guidance Clarifies Health Reimbursement Arrangements Under ACA

Recently issued guidance clarifies the application of certain provisions under the Affordable Care Act (ACA) to health reimbursement arrangements, employer payment plans, health flexible spending arrangements and employee...more

Additional Affordable Care Act Guidance Clarifies Exchange Notices and 90-Day Waiting Period

Recent guidance clarifies the exchange notice requirement and the 90-day waiting period limitation under the Affordable Care Act. The U.S. Departments of Labor (DOL), Health and Human Services, and the Treasury (the...more

Important Reminder Regarding PCORI Fees

An important deadline is looming under the Affordable Care Act (ACA) for employers that sponsor certain self-insured group health plans and issuers of certain health insurance policies. Under the ACA, employers and insurers...more

Final Affordable Care Act Regulations on the Exemption of Contraceptives Coverage by Religious Employers and Student Health...

The final regulations retain the definition of a religious employer, modify the accommodations provided for eligible organizations that object to contraception coverage on religious grounds, and describe how contraceptives...more

Additional Guidance Issued on Summary of Benefits and Coverage Disclosure Requirements

The U.S. Departments of Labor, Health and Human Services, and the Treasury recently issued new guidance and templates regarding the summary of benefits and coverage requirement under the Patient Protection and Affordable Care...more

ACA Guidance on 90-Day Waiting Periods and Certificates of Creditable Coverage

Recently issued Affordable Care Act guidance clarifies the prohibition on waiting periods in excess of 90 days and eliminates the requirement to issue HIPAA group health plan certificates of creditable coverage after December...more

New HIPAA Regulations Require Action by Group Health Plans

Final HIPAA privacy and security regulations issued by the U.S. Department of Health and Human services will require action by group health plan sponsors by September 2013....more

HIPAA De-Identification Guidance

Office of Civil Rights has released additional guidance addressing the de-identification of protected health information in accordance with the HIPAA Privacy Rule. Covered entities should review their current...more

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