If you sponsor or administer a group health plan, you are almost certainly taking steps to prepare for legal requirements that will become effective on or before January 1, 2015. New rules under HIPAA, the Affordable Care Act...more
So much attention has been paid to the issuance of the final employer shared responsibility regulations that some might have missed the news that final regulations were recently issued under another of the Affordable Care...more
Our government managed to reach a deal to avoid another government shutdown. And so, while our tax refunds will continue to be processed and parks remain open, it is that time of year again — the time to review and reflect on...more
In 2013, many different changes in the law impacted group health plans and arguably, even more changes will occur in 2014. The following is an overview of a few of the key compliance issues that occurred in 2013 which should...more
The regulation of marriage was historically presumed to be the exclusive domain of the states. Since 1996, however, the Defense of Marriage Act of 1996 (“DOMA”) changed this presumption in two important respects...more
2013 has already been a busy year for employers with group health plans who are trying to navigate the Affordable Care Act and its immediate implications for employee benefits. However, there are other, less talked about but...more
One theme weaving its way through the multitude of Affordable Care Act (ACA) guidance released over the past few years is this: Employers and group health plans must learn to count, and they must learn to count the "ACA way."...more
The Affordable Care Act’s (ACA’s) employer shared responsibility provisions (commonly called “pay or play”) impact “large” employers and go into effect in 2014. Although effective in 2014, employers must plan NOW. Advance...more
For better or worse, the ACA or Health Care Reform is still with us. If you do not want to end up in the penalty box in 2014, you must know whether you are subject to the employer shared responsibility provisions of the ACA...more
Under the Patient Protection and Affordable Care Act (the “Act”), the federal government, state governments, insurers, employers, and individuals all share responsibility to make affordable health insurance coverage widely...more
It is impossible to ignore. Healthcare reform under the Affordable Care Act is on the minds, agendas and budgets of all employers, and now is the time for employers to review their health programs to address compliance with...more
In This Alert:
- A. What Is The Employer Shared Responsibility Penalty?
- What Is The “Failure To Offer Coverage Penalty”?
- How Is The “Failure To Offer Coverage Penalty” Calculated?
- What Is...more
The U.S. Department of Labor (the "DOL") has recently enhanced its enforcement activities with respect to group health plans by significantly increasing the number of audits it is conducting. In addition, the DOL's audit...more
The Department of Labor has published two checklists that plan sponsors can use to test their compliance with group health plan requirements. One checklist addresses the Affordable Care Act (ACA or health care reform)...more
President Obama’s re-election confirmed that the Affordable Care Act will continue to be rolled out, and that its “pay-or-play” rules will become effective on January 1, 2014. These provisions require public and private...more
The U.S. Department of Labor (DOL) audits already evaluate a company’s compliance on a spectrum of laws, statutes and regulations. However, the DOL has updated and revamped its audit letter to now also capture compliance...more
While the timeline for health care reform calls for a phasing in of its key initiatives and compliance measures over several years, employers who provide health plan benefits — and particularly those who offer open enrollment...more
Let's Talk About Health Care Reform:
Are You Ready to Distribute Summaries of Benefits and Coverage (SBCs)?
Suppose that health insurance policies were written in standard format using common terminology and that it...more
Under the health care reform enacted in 2010 under the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 (referred to collectively here as “PPACA”) new obligations are...more
Now that the Supreme Court has upheld the constitutionality of the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act (collectively, the “Act”), employers must move...more
Even with the lingering uncertainty over Medicaid program expansion, the High Court's decision brings some certainty and the need to focus on ramifications of ACA implementation.
On June 28, the U.S. Supreme Court held...more
The Patient Protection and Affordable Care Act (the “Act”) requires employers to report the cost of coverage under an employer-sponsored group health or medical plan. This requirement was optional for all employers in 2011....more
The Supreme Court’s decision in National Federation of Independent Business v. Sibelius upholding the Patient Protection and Affordable Care Act (PPACA) leaves in place the market reforms and tax provisions that have become...more
Yesterday, June 28, 2012, the U.S. Supreme Court upheld the Patient Protection and Affordable Care Act, with the exception that the Federal government's power to terminate Medicaid funding is to be narrowly read. The main...more
Today the U.S. Supreme Court issued its long-awaited decision on the Patient Protection and Affordable Care Act (ACA). In what is easily the most significant decision this term, and arguably one of the most important rulings...more
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