The Internal Revenue Service (IRS), the Department of Labor (DOL), and the Department of Health and Human Services (HHS), the three federal agencies with primary responsibility for implementing the Affordable Care Act (ACA),...more
The Internal Revenue Service (IRS) has issued an updated version of IRS Form 720 and the instructions. Self-funded group health plan sponsors and health insurers must use this form to report and pay the fee required to fund...more
The Defense of Marriage Act (DOMA) defines marriage at the federal level as a legal union between one man and one woman and excuses states from any obligation to recognize same-sex marriages recognized in any other state. As...more
Beginning in 2014, the Affordable Care Act of 2010 (the "Act") will prohibit group health plans and group health insurers from imposing waiting periods greater than 90 days of employment....more
A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more
The IRS recently released new proposed regulations to implement the Shared Responsibility or “Play or Pay” provisions of Health Care Reform. The proposed regulations provide a wealth of detail on key issues required to...more
Last week the Centers for Medicare & Medicaid Services (CMS) issued new proposed regulations on FY 2014 payment updates and regulatory policy changes for inpatient and long term care hospitals, skilled nursing facilitates,...more
Last Friday the IRS released additional proposed regulations implementing the minimum value requirement for coverage sponsored by employers with 50 or more FTEs. The proposed rules provide that amounts contributed by...more
Health Care Reform: Agencies Issue Proposed Regulations on 90-Day Waiting Period Limitation - On March 21, the IRS, DOL, and Department of Health and Human Services issued proposed regulations on the 90-day waiting...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
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
In a set of Frequently Asked Questions (FAQs) posted to the Department of Labor’s website on January 24, the Departments of Health and Human Services, Labor, and Treasury (the “Departments”) put a stop to an approach to...more
Earlier this month, the IRS issued proposed regulations that provide much-needed guidance on the new “pay or play” rules (also called the shared responsibility rules) that will apply to employers’ group health plans beginning...more
Many important aspects of the Patient Protection and Affordable Care Act ("ACA") will go into effect in 2014, including the implementation of health insurance exchanges, and the requirement for certain employers to offer...more
By far the most important issue for employers to consider under the Affordable Care Act (ACA) is the employer “free rider penalty,” often referred to as “pay or play.” Instead of forcing employers to provide group health...more
Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more
The Internal Revenue Service has released proposed regulations and FAQs on the shared responsibility provisions of the Affordable Care Act (ACA). These rules require large employers to offer full-time employees and their...more
From an employer’s perspective, one of the most important components of the Affordable Care Act (ACA) is the employer shared responsibility provisions. The Internal Revenue Service (IRS) just issued proposed regulations...more
In regulations and other pronouncements issued toward the end of 2012, the government has provided further details on new taxes and fees introduced by the Affordable Care Act (ACA)....more
In This Presentation: - Healthcare - 401(k) Plan Fee Disclosures and Fiduciary Responsibilities - Fair Labor Standards Act - Data Privacy Issues Please see full presentation below for more...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
Under health care reform, employers must report the “aggregate cost” of “applicable employer-sponsored health coverage” on an employee’s Form W-2. The value must first be reported on the Form W-2 issued in January 2013 for...more
The Patient Protection and Affordable Care Act as amended by the Health Care and Education Reconciliation Act of 2010 (together, the “Act”) overhauled much of the country’s health care financing system and marked the...more
On March 29, 2011, the Internal Revenue Service (“IRS”) released Notice 2011-28, which provides guidance to employers on the requirement under the Affordable Care Act (the “Act”) to report the cost of employer-sponsored...more
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