Patient Protection and Affordable Care Act (PPACA) Health Insurance Employer Group Health Plans

The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal... more +
The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal subsidies to reduce the number of uninsured citizens. less -
News & Analysis as of

The Big Picture of the Employer Shared Responsibility Tax

Ever since the Treasury Department in early 2014 issued final regulations on the employer shared responsibility tax (ESR tax)1 and the related final reporting regulations (ESR regulations)2 under the Patient Protection and...more

EEOC Initiates Rulemaking Process for Employer-Sponsored Wellness Programs

Addressing the ongoing controversy over employer wellness programs, which we discussed in a prior alert, the EEOC recently submitted a notice of proposed rulemaking to the White House Office of Management and Budget (OMB)....more

Multiple Departments Issue Guidance on Wellness Programs

The Equal Employment Opportunity Commission (EEOC) made headlines during the second half of 2014 by attacking employers' wellness programs that require employees to undergo certain medical testing or be penalized....more

IRS Traded in Your Chevy for a “Cadillac (ac-ac-ac-ac-ac) Tax”: Agency Issues First Guidance on the Implementation Code Section...

On February 23, 2015, the Internal Revenue Service (IRS) issued the first piece of guidance that discusses the excise tax, better known as the “Cadillac Tax,” imposed by Section 4980I of the Internal Revenue Code of 1986, as...more

Limited Relief for Certain Employer Health Plan Premium Payments or Reimbursements

Under so-called “employer payment plans” (“EPPs”), an employer pays or reimburses an employee for substantiated premium costs under individual health plan insurance coverage (i.e., nonemployer individual health plan...more

IRS Clarifies That After-Tax HRAs and Other Individual Health Insurance Payment Arrangements Generally Violate the Affordable Care...

Any employer who offers an arrangement that reimburses employees (or pays directly) for premiums or other medical costs of individual health insurance coverage, including a health reimbursement account ("HRA") provided in...more

Small Retailers Again Face Increased Health Insurance Costs

The owners of small retail businesses in Massachusetts have come to expect to pay higher health insurance costs than their counterparts in the rest of the country, and unfortunately last year was no exception. ...more

Meet the ACA’s Employer Mandate

After several delays, the Affordable Care Act’s "employer mandate" has begun to take effect. Under the mandate, employers with more than 50 fulltime employees (Large Employers) must offer affordable, minimum essential...more

Obama Administration Finalizes Health Insurance Wraparound Coverage Rule

The Departments of Labor, Health and Human Services, and Treasury published a final rule on March 18, 2015 that amends the definition of excepted benefits to allow group health plan sponsors, in limited circumstances, to...more

BEST IN LAW: Employers need to heed Obamacare Reporting Rules

Compliance with reporting obligations is always important for any employer, but the employer reporting requirements under the Affordable Care Act pack a significant penalty that makes compliance particularly...more

New HHS Regulations “Clarify” that Health Plans Covering Families Must Have “Embedded” Individual Cost-Sharing Limits

On February 27, 2015, the Department of Health and Human Services (HHS) released its final HHS Notice of Benefit and Payment Parameters for 2016. The lengthy regulation covers a wide range of topics affecting group health...more

Short-Term Relief for Small Employers Reimbursing Employee Premiums - But Significant Penalties Loom if You Don’t Stop Soon!

For nearly two years now, the IRS has been explaining that employers are no longer permitted to reimburse employees for premiums the employees paid for individual health insurance coverage....more

IRS Provides Temporary Enforcement Relief for Small Employers Offering Employer Payment Plans

The IRS issued guidance providing enforcement relief through June 30, 2015 for small employers who offer employer payment plans to their employees. In the guidance, the IRS reiterated its stance that an employer payment...more

IRS Releases Preliminary Guidance on “Cadillac Plan” Tax under ACA

The IRS released Notice 2015-16, which represents the first piece of guidance issued by a regulatory agency on the excise tax on high cost employer-sponsored health coverage, colloquially known as the “Cadillac plan” tax. The...more

Final IRS Forms and Instructions for Reporting Health Coverage Clarify Large Employer Requirements for 2015 and Beyond

On February 8, 2015, the IRS released final forms and instructions for reporting health coverage pursuant to Code Sections 6055 and 6056, which were added by the Health Care Reform Act. As stated below, large employers and...more

Monthly Benefits Alert - February 2015

Health & Wellness Plans - Anthem Data Breach Requires Plan Sponsor Attention - On January 29, 2015, Anthem Inc., one of the largest managed health care companies in the country, disclosed that the sensitive...more

Has the Supreme Court Given Advance Notice How It Will Decide King v. Burwell?

On Wednesday, March 4, 2015, the Supreme Court will hear argument in King v. Burwell, the most publicized case in some time. Most readers are aware that the issue is whether certain tax subsidies essential to the proper...more

Could a Cadillac Health Plan Put the Brakes on Obamacare?

The Supreme Court is hearing oral arguments Wednesday, March 4 on certain aspects of the Affordable Care Act. This has the potential to unravel President Barack Obama’s beloved health care plan. Another aspect of...more

Permissible Discrimination in Health Benefits

The intense regulation of health care benefits, especially with respect to the Affordable Care Act, has created much confusion among employers. As a result, many employers do not understand that they may offer different...more

Five Health Care Developments Important to Employers

Perhaps never before have employers faced so many challenges when it comes to health care issues affecting their workforce. Congress may try to amend the Affordable Care Act (“ACA”). The Supreme Court of the United States is...more

Premium Reimbursement Arrangements Get Relief - More ACA Transition Relief—This Time for Small Employers and S-Corps

The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more

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

ACA Countdown to Compliance - 52 Week Series For Employers

In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more

Beware of Stop-Loss Coverage Gaps When Choosing a Self-Funded Major Medical Plan

The Affordable Care Act requires applicable large employers to make broad-based offers of group health insurance coverage to substantially all their full-time employees or face potential tax penalties. (The term “applicable...more

IRS Clarifies Prior Guidance on Premium Reimbursement Arrangements; Provides Limited Relief

Continuing its focus on so-called “premium reimbursement” or “employer payment plans”, the Internal Revenue Service (IRS) released IRS Notice 2015-17 on February 18, 2015. In this Notice, which was previewed and approved by...more

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