Employer Group Health Plans Internal Revenue Service

News & Analysis as of

New ACA Guidance Warrants Another "Checkup" of Employer Health Plans

On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....more

EEOC Loses Another Wellness Case, Part 2 – Beware the ACA Penalties

In my last blog post, I discussed a recent loss by the EEOC in its efforts to limit the ability of employers to require employees to complete health risk assessments (HRAs) or biometric screenings in order to enroll in the...more

Code § 4980H: The Tax The Beatles Missed

The Tax Man, it turns out, also may assess you for failing to offer substantially all your full-time employees and their dependents affordable, qualifying group health coverage during 2015. We’re swamped with employer...more

ACA Reporting Update – The Final Stretch

After months of preparation and multiple iterations of (sometimes conflicting) IRS guidance, health coverage providers and applicable large employers are nearing the end of the 2015 reporting season under the Affordable Care...more

Affordable Care Act Reporting is Here (But May be a Little Late…)

The Affordable Care Act requires “applicable large employers” (generally, employers with 50 or more full-time employees and full-time employee equivalents) to provide individual statements to their full-time employees and to...more

The Affordable Care Act’s Reporting Electronic Backbone—The AIR System

For the last half of 2015, we spent a good deal of time explaining the Affordable Care Act reporting requirements that applied to carriers and large employers. This post examines the how of ACA reporting. In particular, it...more

Employee Benefits & Executive Compensation Advisory: IRS Notice 2015-87 Provides Much-Needed Guidance for Account-Based Plans and...

In IRS Notice 2015-87, the agencies provided further clarification on the impact of the Affordable Care Act (ACA) group health plan market reform provisions on account-based plans and much needed guidance on the Section 4980H...more

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

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

Reminder of the ACA Related Deadlines for 2016

This post is intended to be a brief reminder of some of the 2016 deadlines. As originally described in our December post the following are the updated dates for Forms 1094 and 1095....more

ACA Reporting Deadline Extended — But Employers Should Stay Focused To Avoid Penalties

About a month ago, and just months before the reporting deadlines required under the Affordable Care Act (ACA) were set to go into effect, the Internal Revenue Service gave us all a late Christmas present and announced that...more

Some Welcome Relief and Clarification on Affordable Care Act for Employers

As the federal agencies continue to issue more guidance on the application of various provisions of the Affordable Care Act (the “ACA”) to employer-sponsored health coverage, there are some recent developments that we want to...more

IRS Reduces Voluntary Compliance Program Filing Fees for Most Plans

The IRS recently published its annual update on user fees, Revenue Procedure 2016-8, which now includes fees for Voluntary Compliance Program (“VCP”) applications filed with the IRS pursuant to the Employee Plans Compliance...more

HRA Access for Spouses and Dependents: A New Wrinkle for Form 1095-C

Imagine that you are filling out Internal Revenue Service Form 1095-Cs for 2015 for an employer that offers employees the opportunity to elect self-only or family coverage under a minimum value group health plan. The plan...more

Issue 98: Year-End Agency FAQs Address Many Unanswered ACA Concerns

This is the ninety-eighth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

Employee Benefits: 2015 Ends With a Flurry of ACA Activity (1/16)

Employers were treated to a number of Affordable Care Act (ACA) developments just in time for the holidays and to ring in the New Year. Many of the developments are welcome news for employers, including an extension of the...more

Welcome Holiday Relief for Employers Under the Affordable Care Act in 2016

The U.S. government and federal agencies ended the 2015 winter holiday season by announcing delays to key provisions affecting employers under the Patient Protection and Affordable Care Act (“ACA”)....more

DOL and Treasury Update 2015-2016 Regulatory Agendas for Employee Benefits

The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. On November 19, 2015, the U.S. Department of Labor (DOL) updated its Semi-Annual...more

IRS Extends Affordable Care Act Reporting Deadlines

Last week, the Internal Revenue Service (IRS) granted a reprieve of sorts with respect to the 2015 information reporting requirements under the Affordable Care Act (ACA). Under the ACA, an “applicable large employer”...more

IRS Extends ACA Reporting Deadlines

The IRS issued key extensions to looming 2016 information reporting deadlines for applicable large employers. This relief applies only to the deadlines for reporting the coverage that employers offered in 2015...more

UPDATE: Health Care Reform – End of 2015 Developments Affecting Reporting and Taxation

Pursuant to additional federal guidance issued at the end of 2015, this Advisory supplements our previous advisory regarding important Affordable Care Act (“ACA”) mandates effective in 2016. As explained below, the ACA...more

Alert: Affordable Care Act (ACA) End of Year Checklist

With the Affordable Care Act (“ACA”) nearly fully implemented and agency enforcement now underway, employers must be clear which provisions of the ACA apply to them. Any employer that sponsors a health plan for employees is...more

Group Health Plan Action Items and Reminders for the New Year

While plan sponsors of group health plans breathed a little easier this year-end, there are still important action items and reminders to consider as we look to 2016....more

Deadline Extended For ACA Information Reporting Forms

The IRS has extended the deadlines for furnishing to employees the new Forms 1095 and filing these Forms with the IRS. The Forms are designed to confirm compliance with the employer and individual health insurance mandates...more

Post-Holiday Gift – ACA Reporting Deadlines Relaxed for 2016

We have been shouting the ACA reporting compliance deadlines from the rooftops for months now. Well, I guess it is a case of the “boy who cried wolf”. At the eleventh hour, the IRS has caved to a slew of complaints,...more

IRS Extends 2015 Form 1095 Deadlines

Under the Affordable Care Act (ACA), applicable large employers (generally 50 or more full-time employees in previous year) must furnish each individual who was a full-time employee during 2015 with a Form 1095-C,...more

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