Affordable Care Act, IRS, U.S. Treasury

Notice 2022-41: IRS Expands Mid-Year Cafeteria Plan Change Opportunities to Address “Family Glitch”

Proskauer - Employee Benefits & Executive... on 11/1/2022

On October 11, 2022, the IRS and the Treasury Department released final regulations relating to premium tax credit eligibility for families, along with companion cafeteria plan guidance in Notice 2022-41. The final...more

Fun for the Whole Family: More ACA Subsidies Apply

McDermott Will & Emery on 11/1/2022

On October 11, 2022, the US Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations to modify how affordability under the Affordable Care Act (ACA) is determined for an offer of...more

Treasury Proposes Rule to Fix Family Glitch for ACA Marketplace Coverage

Fisher Phillips on 5/27/2022

The Department of Treasury recently issued proposed regulations to alter the rules for how individuals can get a premium tax credit (PTC) to help pay for Marketplace health coverage starting in 2023. The new rules would base...more

Do Employers Now Have to Offer Affordable Family Coverage?

Jackson Lewis P.C. on 4/11/2022

In furtherance of the Biden Administration’s January 28, 2021, Executive Order 14009 and April 5, 2022, Executive Order 14070 to protect and strengthen the ACA, the Treasury Department and IRS published a proposed rule on...more

New Year, New ACA Reporting Rules

Stoel Rives LLP on 12/2/2021

Since 2015, the Affordable Care Act (“ACA”) has required employers and insurers to annually complete, file with the Internal Revenue Service (“IRS”) and distribute to employees and other covered individuals information about...more

Federal Guidance On Balance Billing: The No Surprises Act And Its Interim Final Rule: Part I

Husch Blackwell LLP on 7/6/2021

On July 1, 2021, the Office of Personnel Management (“OPM”), the Internal Revenue Service (“IRS”), the Department of Treasury (“Treasury”), the Employee Benefits Security Administration (“EBSA”), the Department of Labor...more

Taxpayers That Paid The Net Investment Income Tax Or The Additional Medicare Tax Should Consider Filing Protective Claims For...

McCarter & English, LLP on 7/13/2020

Individuals, estates, and trusts that paid significant amounts of the 3.8% net investment income tax or the 0.9% additional Medicare tax in 2016 or later years should consider filing protective claims for refund of those...more

Weekly IRS Roundup February 3 – 7, 2020

McDermott Will & Emery on 2/11/2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 3 – 7, 2020. February 3, 2020: The IRS and the Departments of Labor and Health and...more

New HRA Regulations Part 5 – More on the Employer Shared Responsibility Mandate

Proskauer - Employee Benefits & Executive... on 10/29/2019

On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more

Staying Healthy: IRS Expands HDHP-HSA Preventive Care Benefits For Chronic Conditions

Fisher Phillips on 9/5/2019

A Health Savings Account (HSA) is a popular vehicle for paying health care costs. Employees find HSAs attractive because they can control the amount of money contributed, determine when to withdraw money, and enjoy the...more

2020 Drug Coupon Rule Dropped Due to Implementation Concerns

Ogletree, Deakins, Nash, Smoak & Stewart,... on 8/28/2019

Employer plans will still be able to exclude the value of drug manufacturer coupons from annual out-of-pocket maximums, even when no generic equivalent is available, under new guidance from the Department of Labor, Department...more

New HRA Rules: What Employers Need to Know

Ogletree, Deakins, Nash, Smoak & Stewart,... on 7/17/2019

Starting in 2020, employers will be able to offer health reimbursement arrangements (HRAs) that work in conjunction with individual coverage or Medicare without running afoul of the Affordable Care Act’s (ACA) market reform...more

What the HRA is going on with HRAs?

Burr & Forman on 7/11/2019

On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

Agencies Issue Final Regulations Expanding Access to Health Reimbursement Arrangements

Mintz - Employment Viewpoints on 7/11/2019

On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more

New Final Rules Permit Individual Coverage Health Reimbursement Arrangements

Holland & Knight LLP on 7/9/2019

• The U.S. Departments of Health and Human Services, Labor and the Treasury (collectively, the Departments) issued Final Rules regarding a new type of health reimbursement arrangement (HRA) – the individual coverage HRA...more

Will Grandfathered Plans be Rescued?

Mintz - Employment Viewpoints on 3/21/2019

On February 25, 2019 the Department of Labor, Department of Health and Human Services, Treasury Department and the Internal Revenue Service (the “Departments”) published a request for information (the “ROI”) on grandfathered...more

IRS Releases Interim Guidance on New Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations

Proskauer - Not for Profit/Exempt... on 1/15/2019

On December 31, 2018, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released Notice 2019-09 (the “Notice”), which provides interim guidance under Section 4960 of the Internal Revenue...more

IRS Opens Discussion On Broadening The Use Of HRAs

Laner Muchin, Ltd. on 12/19/2018

In October 2018, the Departments of Treasury, Labor, and Health and Human Services issued proposed regulations expanding the availability of Health Reimbursement Arrangements (HRAs) by eliminating a prohibition on integrating...more

The ERISA Litigation Newsletter - June 2016

Proskauer Rose LLP on 7/1/2016

Editor's Overview - In this month’s newsletter, our colleagues focus on two sets of legislative updates. First is a discussion of the IRS’s proposed Treasury Regulations prescribing rules under Section 457 of the...more

The ERISA Litigation Newsletter - May 2016

Proskauer Rose LLP on 6/1/2016

Editor’s Overview - In this issue of Proskauer's ERISA Litigation Newsletter, we review a recent ruling by the Tenth Circuit Court of Appeals concerning the application of controlled group principles to the building...more

New ACA, et. al. FAQs Cover Items From “Top” to “Bottom”

BCLP on 4/28/2016

On April 20, the “Big Three” agencies (DOL, Treasury/IRS, and HHS) released another set of FAQs (the 31st, for those of you counting at home). Consistent with earlier FAQs, the new FAQs cover a broad range of items under the...more

Student Health Plans and ACA Compliance: New Relief for Educational Institutions

Ogletree, Deakins, Nash, Smoak & Stewart,... on 2/26/2016

Educational institutions face unique issues when complying with the requirements of the Affordable Care Act (ACA). One such issue relates to the administration of student health insurance plans. On February 5, 2016, three...more

Integrated Health Reimbursement Accounts, Coordination with Family Coverage, and Notice 2015-87—Something’s Missing

Mintz - Employment, Labor & Benefits... on 2/3/2016

Issued at the end of last year, Notice 2015-87 provided detailed guidance on a host of topics. The notice has been referred to colloquially in some quarters as the “pot luck” notice. Among other things, the notice, in Q&A 4,...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 23 of 24): Notice 2016-4 Postpones Reporting and...

Mintz - Employment, Labor & Benefits... on 12/29/2015

Under the Affordable Care Act’s reporting requirements that have been the subject of this series, statements to responsible individuals (a/k/a “employees”)—i.e., Forms 1095-B and 1095-C—must be furnished on or before January...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

Mintz - Employment, Labor & Benefits... on 11/3/2015

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

Patient Protection and Affordable Care Act (PPACA) › Internal Revenue Service › U.S. Treasury

"My best business intelligence, in one easy email…"