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COBRA Premium Subsidies - A Little More Guidance (and a Reminder)

The IRS issued a new notice that provides guidance on a few issues that were not fully addressed in its earlier notice on the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy requirements set forth in...more

IRS Provides Flexibility for Employer-Sponsored Health Plans and FSAs in Response to COVID-19 Pandemic

The Internal Revenue Service (IRS) has issued new guidance, Notice 2020-29, in response to the COVID-19 pandemic, providing for temporary flexibility with respect to mid-year elections made during 2020 under Code section 125...more

IRS Prepares to Enforce ACA Employer Mandate

The IRS has announced its intent to begin enforcing the employer-shared responsibility provisions (otherwise known as the employer mandate or pay-or-play provisions) of the Affordable Care Act for the 2015 calendar year....more

CMS, IRS Address Affordable Care Act Issues in Transition

The Centers for Medicare and Medicaid Services (CMS) and the IRS have each published guidance on matters arising under the Affordable Care Act (ACA). It is too early to tell whether these measures—some of the first guidance...more

Ballard Opinion Letter Program to Replace IRS Determination Letter Program

The Internal Revenue Service has largely ended its determination letter program by which sponsors of individually designed retirement plans can obtain confirmation that their plan documents are tax-qualified. The IRS has...more

IRS Seeks to Curb Popularity of ‘Skinny’ Health Plans

The Internal Revenue Service, in Notice 2014-69, has concluded that certain unconventional group health plan designs that offer limited or no coverage for in-patient hospitalization services and/or physician services will not...more

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

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

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

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

Final Mental Health Parity Act Regulations Released

The Internal Revenue Service, U.S. Department of Labor, and U.S. Department of Health and Human Services have jointly released final regulations and new FAQs implementing the Paul Wellstone and Pete Domenici Mental Health...more

Expanded Contraception Coverage Exemption for Religious Organizations Proposed by HHS and IRS

The U.S. Departments of Health and Human Services and Treasury have released proposed regulations, a fact sheet, and a press release on the Affordable Care Act contraceptives coverage under Women's Preventive Health Services...more

IRS Releases Further Guidance on Employer Health Care Coverage Mandate and Penalties

The Internal Revenue Service has released proposed regulations and FAQs on the shared responsibility provisions of the Affordable Care Act (ACA). These rules require large employers to offer full-time employees and their...more

Government Agencies Provide Guidance on Taxes and Fees under the Affordable Care Act

In regulations and other pronouncements issued toward the end of 2012, the government has provided further details on new taxes and fees introduced by the Affordable Care Act (ACA)....more

Final Rules Issued for Health Care Reform Tax on Medical Devices, Effective January 1, 2013

The Internal Revenue Service (IRS) released final regulations and other guidance on the excise tax applicable to the sale of certain medical devices under the Affordable Care Act. Beginning January 1, 2013, a tax of 2.3...more

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