Edward I. Leeds

Edward I. Leeds

Ballard Spahr LLP

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IRS Issues New Forms for ACA Reporting; Congress Increases Penalties for Failure to Meet Requirements

The IRS has completed drafts of the 2015 forms and instructions for employers, insurers, and other health plan sponsors to use to meet their reporting obligations for the employer and individual mandates under the Affordable...more

8/14/2015 - Affordable Care Act Compliance Employee Benefits Health Insurance Healthcare Insurance Industry IRS Popular Reporting Requirements Trade Preferences Extension Act (TPEA)

IRS Issues Second Guidance on Cadillac Tax

The Internal Revenue Service has issued a new notice addressing issues relating to future rules governing the calculation and payment of the so-called “Cadillac tax” under the Affordable Care Act. Beginning in 2018, the ACA...more

8/4/2015 - Affordable Care Act Cadillac Tax Employee Benefits Employer Group Health Plans Health Savings Accounts Healthcare Healthcare Reform IRS

Final Rules for Preventive Services

The U.S. Departments of Treasury, Labor (DOL) and Health and Human Services (HHS) have issued interim final regulations and Frequently Asked Questions and Answers on the cost-free coverage of preventive services under the...more

8/3/2015 - Affordable Care Act Burwell v Hobby Lobby Closely Held Businesses Contraceptive Coverage Mandate Corporate Governance DOL Health Insurance Healthcare HHS Hobby Lobby Preventive Health Care Privately Held Corporations Religious Institutions U.S. Treasury

Supreme Court Upholds Affordable Care Act Subsidies in King v. Burwell

In a much-anticipated decision, the U.S. Supreme Court ruled today that individuals who enroll for coverage in a health insurance exchange may qualify for a subsidy to make that coverage more affordable, regardless of whether...more

6/26/2015 - Affordable Care Act Health Insurance Health Insurance Exchanges Individual Mandate King v Burwell SCOTUS State Health Insurance Exchanges Subsidies Tax Credits

New Guidance on Cost-Sharing Limits and Provider Nondiscrimination Rules

The U.S. Departments of Labor, Health and Human Services, and the Treasury have jointly issued a new set of FAQs that clarifies the application of the rules establishing cost-sharing limits. For 2016, non-grandfathered group...more

5/29/2015 - Affordable Care Act Cost-Sharing DOL Health Insurance Healthcare HHS U.S. Treasury

Guidance Clarifies Preventive Care Requirements

Recent guidance issued jointly by the U.S. Departments of Labor, Health and Human Services, and the Treasury clarifies how the Affordable Care Act's requirement to provide cost-free coverage for preventive care applies to...more

5/14/2015 - Affordable Care Act DOL Health Care Providers Health Insurance Healthcare HHS New Guidance Preventive Health Care U.S. Treasury

EEOC Tackles Wellness Programs

After much silence, some litigation, and recent congressional hearings, the Equal Employment Opportunity Commission (EEOC) has at long last proposed regulations (together with a fact sheet and set of frequently asked...more

4/23/2015 - ADA Affordable Care Act EEOC Employer Group Health Plans HIPAA Proposed Regulation Wellness Programs

IRS Issues Preliminary Guidance on Cadillac Tax

Monday, the Internal Revenue Service issued preliminary but much-anticipated guidance on the so-called Cadillac tax imposed by the Affordable Care Act (ACA). The new notice offers very few concrete answers to employer...more

2/26/2015 - Affordable Care Act Cadillac Tax IRS New Guidance

IRS Issues Final Forms for Affordable Care Act Reporting

The Internal Revenue Service has finalized the forms and instructions for reporting information necessary for enforcement of the individual and employer mandates under sections 6055 and 6056 of the Internal Revenue Code. The...more

2/26/2015 - Affordable Care Act Employer Mandates Forms IRS Reporting Requirements

Partial Relief for Employer Payment of Individual Insurance Premiums

In a recent notice, the Internal Revenue Service has tempered prior guidance that closed the door on employer arrangements for paying the cost of individual health insurance for employees. The IRS still views these premium...more

2/26/2015 - Affordable Care Act Corporate Counsel Employer Group Health Plans Health Insurance IRS Medical Reimbursement Plans Medicare Medicare Part A Medicare Part B TRICARE Waivers

Expatriate Plans Exempted from Many Affordable Care Act Provisions

In the Consolidated and Further Continuing Appropriations Act (the recently enacted federal budget bill often known as the “CRomnibus” legislation), Congress has exempted health plans designed to cover expatriates from most...more

1/12/2015 - Affordable Care Act Appropriations Bill Employer Group Health Plans Employer Mandates Expatriates Foreign Nationals

Student Employees under the Affordable Care Act's Employer Mandate

Effective January 1, 2015, colleges and universities will need to comply with the employer mandate under the Affordable Care Act, which will have particular implications involving certain student employees. The employer...more

11/5/2014 - Affordable Care Act Employee Rights Employer Mandates Student Employees Students

Health Plan ID Requirements and Other End-of-Year Considerations

Employers and other health plan sponsors may be focused on preparing for the commencement of the employer mandate under the Affordable Care Act on January 1, 2015, but a number of other deadlines and developments are emerging...more

10/13/2014 - Affordable Care Act Benefit Plan Sponsors Cafeteria Plans Employer Mandates HPID IRS Look-Back Measurement Period Popular Reporting Requirements

IRS Issues More Guidance on Affordable Care Act Reporting Requirements

Following up on regulations and forms published earlier this year, the IRS has issued instructions and other guidance on the shared responsibility reporting requirements under the Affordable Care Act....more

9/4/2014 - Affordable Care Act IRS Reporting Requirements

IRS Issues Draft ACA Reporting Forms

The Internal Revenue Service recently released draft versions of the forms that will be used to meet the shared responsibility reporting requirements under the Affordable Care Act (ACA). These draft forms have been released...more

7/30/2014 - Affordable Care Act Employer Mandates Filing Requirements Forms Individual Mandate IRS Public Comment Reporting Requirements

Federal Courts Make Conflicting Rulings on Premium Assistance for Federal Exchange Plan Participants

Does the Affordable Care Act (ACA) authorize the payment of premium and copayment subsidies, or “premium assistance subsidies,” to individuals enrolled in a federally established Exchange? On July 22, 2014, two federal courts...more

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

Midyear Check on Health Plan Compliance

If you sponsor or administer a group health plan, you are almost certainly taking steps to prepare for legal requirements that will become effective on or before January 1, 2015. New rules under HIPAA, the Affordable Care Act...more

7/15/2014 - Affordable Care Act Compliance Employer Group Health Plans Healthcare

Religious Freedom Law Exempts Employers from ACA Contraceptive Mandate, Supreme Court Holds

The U.S. Supreme Court has ruled in favor of three for-profit corporations that claimed that the Affordable Care Act (ACA) mandate to provide preventive care coverage for certain types of contraception violated the...more

7/3/2014 - Affordable Care Act Burwell v Hobby Lobby Contraceptive Coverage Mandate Contraceptives Healthcare Reform HHS Hobby Lobby Religious Exemption Religious Freedom Restoration Act SCOTUS

New FAQs Address Effect of Affordable Care Act on COBRA and Other Matters

In a wide-ranging set of frequently asked questions (FAQs) and other guidance, the U.S. Departments of Labor, Treasury, and Health and Human Services have addressed a number of issues pertaining to the Affordable Care Act...more

5/8/2014 - Affordable Care Act CHIPRA COBRA Corporate Counsel Cost-Sharing DOL FSA Healthcare HHS Preventive Health Care U.S. Treasury

HHS and IRS Release Updates on the SHOP Marketplace, Fees, Taxes, and Payment Parameters

Before departing for the 2013 Thanksgiving holiday, the Obama administration released several new regulatory announcements and guidance relating to the implementation of the Affordable Care Act (ACA). The new guidance delays...more

12/11/2013 - Affordable Care Act Fees Healthcare Healthcare Reform HHS IRS Medicare Taxes SHOP Program TPAs

Effective Date of ACA Employer Mandate (Pay or Play) is Postponed

In a startling development, the federal government appears ready to delay by one year the effective date of one of the central provisions of the Affordable Care Act (ACA)—the shared responsibility provisions (more commonly...more

7/3/2013 - Affordable Care Act Delays Employer Mandates Pay or Play Shared Responsibility Rule Tax Penalties U.S. Treasury

Final Regulations Issued on Contraceptive Coverage, Religious Organizations

The U.S. Departments of Health and Human Services, Labor, and Treasury recently released final regulations on the exemption from providing coverage for contraceptive and certain other preventive services that is available to...more

7/2/2013 - Affordable Care Act Contraceptive Coverage Mandate Exemptions Healthcare HHS Religious Institutions

IRS Revises Form for Payment of Fee To Fund Patient-Centered Outcomes Research

The Internal Revenue Service (IRS) has issued an updated version of IRS Form 720 and the instructions. Self-funded group health plan sponsors and health insurers must use this form to report and pay the fee required to fund...more

6/11/2013 - Affordable Care Act Employer Group Health Plans Fees Form 720 IRS PCORI

More Guidance Issued on Summaries of Benefits and Coverage

The U.S. Department of Labor has issued a set of frequently asked questions, together with a new template, for the Summary of Benefits and Coverage (SBC) that applies to group health plans and individual health insurance. The...more

4/26/2013 - Affordable Care Act DOL Employer Group Health Plans Healthcare SBC

Agencies Propose Regulations on the 90-Day Waiting Period Requirement

The U.S. Departments of Health and Human Services, Labor, and Treasury have released a joint set of proposed regulations implementing the requirement in the Patient Protection and Affordable Care Act that group health plans...more

3/20/2013 - Affordable Care Act Eligibility Employer Group Health Plans Healthcare HHS Pay or Play Waiting Periods

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