News & Analysis as of

Patient Protection and Affordable Care Act (PPACA) Reporting Requirements 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 -
Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Fisher Phillips

5 Most Important Steps for Employers Doing Their 2023 ACA Compliance Planning

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Applicable large employers must adhere to many Affordable Care Act (ACA) rules to remain compliant regarding group health plan offerings. We offer the following checklist of the five most helpful reminders you should take...more

Jackson Lewis P.C.

Dealing With Undocumented Workers In ERISA Plans

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Whether because of the tight U.S. labor market or flawed onboarding processes, many undocumented workers are becoming participants and accruing benefits in ERISA-governed employee benefit plans. Dealing with such plan...more

Woodruff Sawyer

Compliance Alert: IRS Proposes Permanent 30-day Extension to ACA Reporting Deadline

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Insights December 3, 2021 /Employee Benefits On November 22, 2021, the IRS filed a Notice of Proposed Rulemaking (“Proposed Rule”) that among other things, provides for an automatic 30-day extension of the deadline for...more

Bradley Arant Boult Cummings LLP

IRS Proposes Regulations on ACA Reporting: Good News and Bad News for Employers

The Internal Revenue Service (IRS) has published proposed regulations that, if finalized, will ease some of the requirements imposed on employers reporting offers of minimum essential health coverage, including a permanent...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

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Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Guidance Delays Some Key CAA and Other Health Benefit Effective Dates

New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly - but only slightly - more manageable heading into 2022....more

Snell & Wilmer

Ready or Not, Mental Health Parity Reporting Has Been Effective Since February 10, 2021

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On April 2, 2021, the Labor, Treasury, and Health and Human Services departments (the “Departments”) issued ACA FAQs Part 45 (“FAQ 45”), which elaborates on the new reporting requirements implemented by the Consolidated...more

Dickinson Wright

Reporting Health Care Costs on Form W-2—The Devil is in the Details

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The Affordable Care Act (ACA) requires employers who file 250 or more W-2s to report the cost of coverage under an employer-sponsored group health plan on an employee’s W-2.This is reported in Box 12, with Code DD....more

McAfee & Taft

IRS announces relief for certain Form 1094/1095 reporting requirements

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In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more

Foley & Lardner LLP

IRS Says ACA’s Employer Mandate is a Forever Liability – What Should Large Employers Do Now?

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Takeaway Message: The IRS has recently concluded that the Affordable Care Act’s (the “ACA”) employer mandate is an ongoing tax liability which cannot be extinguished with the passage of time. In other words, the IRS has no...more

Epstein Becker & Green

IRS Memo Concludes No There Is Statute of Limitations for ACA Employer Mandate Penalties Under Internal Revenue Code § 4980H

The IRS Office of Chief Counsel recently issued a memo which, in a surprise to many, concluded that the filing of the Affordable Care Act (“ACA”) Forms 1094-C and 1095-C (“C Forms”) does not start the statute of limitations...more

Burr & Forman

Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row

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Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is necessary in order for the IRS to administer certain portions of...more

Jackson Lewis P.C.

Employers In Union-Related Group Health Plans Must Still Comply With ACA Reporting Requirements

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Employers who provide health benefits to their union workforce through a multiemployer group health plan must satisfy all the Affordable Care Act (ACA) reporting requirements regarding their union employees. Employers...more

Proskauer - Employee Benefits & Executive...

IRS Extends ACA Reporting Deadline and Issues Transition Relief

The IRS has not yet finalized the ACA reporting forms (i.e., the 1094-B/C and 1095-B/C) for the 2019 tax year, so it is no surprise that the IRS issued guidance this week extending the deadline to furnish the forms to...more

Proskauer - Employee Benefits & Executive...

New Jersey Individual Mandate Requires State Filings in March 2020

The Affordable Care Act’s individual mandate (i.e., the requirement that most individuals obtain adequate health insurance or pay a penalty) is dead. A side effect of the ACA mandate’s demise is that states are beginning to...more

Proskauer - Employee Benefits & Executive...

Massachusetts Health Insurance Responsibility Disclosure Form Must Be Filed by November 30 and Annually Thereafter

Massachusetts recently published guidance regarding its new Health Insurance Responsibility Disclosure (HIRD) annual filing, which is due for the first time on November 30, 2018 and then annually thereafter. This new HIRD...more

Mintz - Employment Viewpoints

Association Health Plan Perspectives (Part 2): The Look-Through Rule and the Limits of State Regulatory Power

In a summary of the recently issued Association Health Plan (AHP) final regulations, the U.S. Department of Labor (DOL) rightly observed that AHPs are a species of multi-employer welfare arrangements, or MEWAs, that are...more

Stinson LLP

Association Health Plans Present Opportunities for Employers

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New guidance helps plan sponsors and employers manage and operate AHPs - The Department of Labor (DOL) and Internal Revenue Service (IRS) recently released guidance related to the DOL's June 28th final rule on association...more

Carlton Fields

A Game Plan for Employers Facing Possible ACA Penalties

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All employers are at risk of receiving a notice from the IRS that they are liable for a penalty under the Affordable Care Act for failing to offer enough employees insurance coverage, or for failing to offer particular...more

Mintz - Employment Viewpoints

Massachusetts to (Again) Require Health Care Reporting by Employers

Massachusetts employers with 6 or more employees will soon be required to prepare and file a new health care reporting form referred to as the “healthcare coverage form.” While reminiscent of the now repealed “Health...more

Foley & Lardner LLP

Thank You IRS - Extensions for This Year’s ACA Tax Reporting

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The “Bottom Line” - Employers will have until March 2, 2018 to furnish Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”) to employees.,,...more

Proskauer - Employee Benefits & Executive...

IRS Once Again Extends Distribution (Not Filing) Deadline for ACA Reporting and Continues Good Faith Standard

Following the old “better late than never” axiom, the IRS recently announced (see Notice 2018-06) that once again it would be extending the distribution (but not filing) deadline for the Affordable Care Act (ACA) reporting...more

Fisher Phillips

President Trump Once Again Attempts To Dismantle The Affordable Care Act

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After multiple failed attempts by Congress to reform the Affordable Care Act (ACA), President Trump announced several weeks ago that the federal government would stop making subsidy payments to insurers who sell coverage...more

Fisher Phillips

Brace for Impact: IRS Says ACA Employer Mandate Penalties Coming

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The IRS quietly revised its FAQ on employer shared responsibility provisions under the Affordable Care Act (ACA) in November, adding a bombshell statement that it plans to inform employers of their “potential liability for an...more

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