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Stimulus Bill Adds New Disclosure Requirements for Consultants and Brokers to ERISA Health Plans

The new stimulus bill (the Consolidated Appropriations Act of 2021 or CAA) imposes new disclosure requirements for brokers and consultants providing services to ERISA health plans. The service providers are required to...more

House Passes American Health Care Act

As widely reported, the U.S. House of Representatives has passed the American Health Care Act (AHCA), a bill that, if enacted, would make the first major legislative changes to the Affordable Care Act (ACA). Modified to...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

Supreme Court Restricts State Medical Claims Data Reporting Law

ERISA does not allow a state to compel a self-insured group health plan to compile and report medical claims data for inclusion in a state-wide all-payer health care database, the U.S. Supreme Court has ruled in a landmark...more

Cadillac Tax Delayed, Made Deductible

In the first significant congressional modification of the Affordable Care Act (ACA) since its passage, the notorious "Cadillac tax" on high-cost employer health plans has been delayed two years, from 2018 to 2020. The delay...more

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

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

New IRS Guidance Modifies the ‘Use-It-or-Lose-It’ Rules for Health Flexible Spending Accounts

The Internal Revenue Service will now allow an employer-sponsored health flexible spending account (FSA) program to permit the carryover of up to $500 in unused health FSA funds from one year to the next. ...more

Treasury Proposes Minimum Value Rules for Health Plans

The U.S. Department of the Treasury has published proposed regulations that provide guidance on how an employer may determine whether its group health plan provides “minimum value.”...more

President Obama Proposes Plan To Encourage Private Investment in Infrastructure

President Obama recently announced the Rebuild America Partnership plan (RAPP), a bipartisan effort focused on rebuilding the nation’s aging infrastructure and driving economic growth. Through RAPP, the President proposes to...more

New Guidance Addresses Individual Shared Responsibility Payments and Premium Tax Credits

The IRS and the U.S. Department of Health and Human Services (HHS) have issued two important pieces of guidance under the Patient Protection and Affordable Care Act regarding the responsibilities imposed on individuals to...more

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