Cynthia Moore

Cynthia Moore

Dickinson Wright

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Latest Publications


Employer Paid Individual Health Insurance Policies Create the Potential for Significant Penalties, But Limited Relief Is Available

Despite guidance from the Internal Revenue Service (“IRS”), the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) indicating the prohibition of the practice under the Affordable Care Act...more

5/29/2015 - Affordable Care Act DOL Employer Group Health Plans Health Insurance HHS IRS Medical Reimbursement Penalties Popular S-Corporation SHOP Program

U.S. Supreme Court Decision on ERISA Fiduciary Duty Statute of Limitations Case Provides Broad Principle But Little Practical...

Last week the U.S. Supreme Court issued its opinion in Tibble v. Edison International, a highly anticipated case involving whether ERISA’s six year statute of limitations for breach of fiduciary duty claims prevented a claim...more

5/28/2015 - Breach of Duty Duty of Prudence Duty to Monitor ERISA Fiduciary Duty Investment Adviser SCOTUS Statute of Limitations Tibble v Edison Int

Deadline Approaching to Secure Health Plan Identifier (“HPID”)

Certain group health plans are required to obtain a 10-digit Health Plan Identifier ("HPID") from the Center for Medicare and Medicaid Services ("CMS") by November 5, 2014. Currently various users of the health care system...more

10/29/2014 - CMS FSA Healthcare HIPAA HPID HSA Medicaid Medicare

The HIPAA “Omnibus” Final Rule Part II - Revisions to Business Associate Definition, Liability and Obligations, Certain Individual...

The United States Department of Health and Human Services (the “Department” or “HHS”) issued the “Omnibus” Final Rule (the “Final Rule”) on January 17th, 2013. The Final Rule contains long-awaited rules and clarifications...more

3/1/2013 - Business Associates GINA HHS HIPAA HIPAA Omnibus Rule HITECH PHI

Penalties and Measuring Periods for Large Employers - How to Assess Potential Liability under the Affordable Care Act

Under the Affordable Care Act (“ACA”), a large employer is subject to penalties if it fails to offer to full-time employees and their dependents health coverage or if the coverage that it offers is not affordable or does not...more

2/18/2013 - Affordable Care Act Employer Liability Issues Essential Health Benefits Full-Time Employees Hour of Service IRS Look-Back Measurement Period New Hires Penalties Shared Responsibility Rule Tax Credits

Determining if the Affordable Care Act “Play or Pay” Rules Apply to a Business

Under the Affordable Care Act, a large employer is subject to penalties if it fails to offer to full-time employees health coverage or if the coverage that it offers is not affordable or does not provide minimum value. These...more

1/23/2013 - Affordable Care Act Full-Time Employees IRS Pay or Play Seasonal Employment Shared Responsibility Rule

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