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Three Facts Every Employer Should Know about Code Section 4980H Penalties

If you need help determining whether you are an “applicable large employer” subject to these rules or estimating the extent of potential penalty exposure, our Employer Shared Responsibility Penalty Checklist for Employers may...more

Final Touches: IRS Clarifies Impact of COVID-19 Disaster Relief on COBRA Payment Deadlines

The Internal Revenue Service recently issued guidance to clarify the interaction between COVID-19 disaster relief and premiums due for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985...more

For the Long Haul: SCOTUS Ruling Means ACA Coverage and Reporting Rules Here to Stay

Despite myriad legal challenges, the Affordable Care Act (“ACA”) remains the law of the land. We previously reported on the Supreme Court’s latest validation of the law in our SW Benefits Update, “Three Strikes You’re Out –...more

Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act

The American Rescue Plan Act (“ARPA”) has been the law of the land since March 11, 2021. Even so, many questions remained unanswered with respect to ARPA’s impact on group health plans. To resolve some of the lingering...more

DOL Clarifies Key Provisions, Issues Model Notices for COBRA Relief Under ARPA

On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”). We previously summarized the provisions of ARPA that significantly and immediately impact group health plans in our SW Benefits Update,...more

2021 Consolidated Appropriations Act Compliance Checklist for Plan Sponsors

On December 27, 2020, former President Trump signed the Consolidated Appropriations Act, 2021 (the “CAA”) into law. The CAA includes numerous provisions that impact employer-sponsored group health plans, including the...more

“Help Is on the Way” – Important Changes to COBRA Under the American Rescue Plan Act

In an effort to combat the effects of the COVID-19 pandemic, Congress passed and President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”). Among many other provisions, ARPA contains changes that...more

Reassigning Section 1557: Trump Administration Proposes Reversal of Transgender Benefits Rule

In 2016, the Department of Health and Human Services (“HHS”) Office of Civil Rights issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act (“Section 1557”), which prohibit the...more

The 95 Percent Test: Gearing up for Another Round of Employer Shared Responsibility Penalties

Late last year, the Internal Revenue Service (the “Service”) began enforcing penalties with respect to failures to comply with the employer shared responsibility provisions of Section 4980H of the Internal Revenue Code. In...more

2017 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare

As 2017 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are presenting our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 will cover...more

Transgender Benefits Revisited?

In a series of tweets published on July 26, 2017, President Trump announced a ban on transgender service in the armed forces. In the wake of this reversal of government policy, employers may question the current state of...more

A Little Breathing Room: IRS Extends ACA Reporting Deadline and Good Faith Penalty Relief

The IRS delivered welcome news to employers gearing up to meet the Affordable Care Act’s (“ACA”) information reporting deadlines for the 2016 calendar year. In Notice 2016-70, the IRS extended the deadline to furnish Forms...more

A Deeper Dive: Employers Receiving Federal Funding May Be Subject to ACA’s Nondiscrimination Rule and Need to Cover Transgender...

In recent months, we have written a fair amount about providing transgender benefits in light of the nondiscrimination provisions of the Affordable Care Act. Our blogs of March 30, 2016 and June 22, 2016 highlight the key...more

Departments Finally Publish Updated SBC Template and Instructions

On April 6, 2016, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued an updated Summary of Benefits and Coverage (“SBC”) template. The latest template represents an effort by the...more

Transitioning to Coverage: Three Things to Know About the New Transgender Healthcare Regulations

On May 18, 2016, the Department of Health and Human Services (“HHS”) issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act. As we discussed in our March 30, 2016 blog, the rule...more

2015 End of Year Plan Sponsor “To Do” List Health & Welfare

As 2015 comes to an end, we are pleased to present you with our traditional End of Year Plan Sponsor “To Do” Lists. Like last year, we are presenting our “To Do” Lists in three separate Employee Benefits Updates. Part 1 of...more

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