News & Analysis as of

Employer Group Health Plans Pay or Play

McDermott Will & Emery

A New Day for the HRA

McDermott Will & Emery on

The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other...more

Mintz - Employment Viewpoints

Efforts to Shore up MassHealth Should Favor Simplicity and Avoid Potential Conflict with Federal Law

In an effort to make up for a funding shortfall in the Commonwealth of Massachusetts’ Medicaid program, state policymakers have proposed solutions that include a “play-or-pay” option under which employers who fail to offer...more

BakerHostetler

The Stealth Excise Tax Under Section 4980D of the Internal Revenue Code

BakerHostetler on

Most employers are by now well aware of the “pay or play” penalties that may apply if the employer fails to offer coverage to substantially all of its full-time employees or offers coverage that fails to be affordable for...more

King & Spalding

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

King & Spalding on

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

Blank Rome LLP

U.S. Supreme Court Upholds Obamacare Premium Tax Subsidies

Blank Rome LLP on

Action Item: Yesterday's Supreme Court ruling to uphold the premium tax subsidy regime of the Affordable Care Act is of critical importance to individuals and employers alike regarding the availability of federal tax...more

Mintz - Employment, Labor & Benefits...

ACA Countdown to Compliance - 52 Week Series For Employers

In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more

Akerman LLP - Health Law Rx

ACA Issues for Employers to Stay Aware of in 2015

With the Affordable Care Act's Employer Mandate (Pay-or-Play penalties) now officially in effect, employers with 50 or more full-time or full-time-equivalent employees should have already made all significant changes to their...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 3: Group Health Plan, Cafeteria Plan and Health FSA...

As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 5: Health and Human Services (HHS) Wastes No Time Issuing...

Over the last couple of months, we have followed and reported on a particular ACA compliance strategy under which an employer subject to the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 7: IRS Puts the Kibosh on Health Plans that Fail to Cover...

In a previous post, we described an Affordable Care Act compliance strategy—referred to commercially as a “minimum value plan” or “MVP”—that involves an offer of group health plan coverage that, while similar in most respects...more

Faegre Drinker Biddle & Reath LLP

New Guidance on Employment-Based Orientation Periods

As employers who sponsor group health plans well know, health care reform prevents plans from imposing waiting periods in excess of 90 days for employees who are otherwise eligible to enroll in a plan. The latest guidance...more

Faegre Drinker Biddle & Reath LLP

Pay-or-Play: Think Globally

With the effective date of the “pay-or-play” employer mandate just over the horizon, employers who sponsor group health plans are well aware of the layers of complexity presented by the mandate. One of the layers that...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 43: Coordinating the 3-Month Delay under Employer Shared...

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

Foley & Lardner LLP

Final “Pay or Play” Regulations Provide Transition Relief for Non-Calendar Year Plans

Foley & Lardner LLP on

Last week, the IRS issued final regulations that provide additional guidance on the new “pay or play” rules (also called the employer shared responsibility rules) that will generally apply to employers’ group health plans...more

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

MA Fair Share Contribution, HIRD Repealed In FY2014 Budget

Governor Deval Patrick recently approved the Commonwealth’s 2014 fiscal year budget, which includes provisions repealing both the Fair Share Contribution (FSC) and the Health Insurance Responsibility Disclosure (HIRD) form...more

Foley & Lardner LLP

ACA’s “Pay-Or-Play” Penalty Delayed Until 2015

Foley & Lardner LLP on

Last week, in a move welcomed by many employers, the Obama administration announced that it would delay implementation of certain key provisions of the Affordable Care Act (ACA) until 2015....more

Polsinelli

ACA "Pay Or Play" Deadline Extension — What It REALLY Means

Polsinelli on

On July 2, 2013, the U.S. Treasury announced that the Obama Administration is implementing a one-year delay of the employer and insurer reporting requirements under the Affordable Care Act of 2010 ("ACA"). ...more

Littler

ACA Employer Play or Pay Requirements: What Does it Mean for Employers?

Littler on

Beginning in 2014, the Affordable Care Act (ACA) will require “large” employers to offer their full-time employees healthcare coverage that meets certain standards or pay a penalty. Whether an employer opts to “play-or-pay”...more

Buchalter

Pay or Play? What Employers Need to Know About the Affordable Care Act

Buchalter on

- What does the Affordable Care Act (aka “Obamacare”) require of employers in 2014? Beginning January 1, 2014, every “large employer” will be subject to Affordable Care Act penalties if at least 95 percent ...more

Saul Ewing LLP

The Benefits Game - Playbook for Compliance with the Health Care Reform’s Pay or Play Rules for Employers

Saul Ewing LLP on

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

Proskauer - Employee Benefits & Executive...

The View From Proskauer: Health Care Reform Litigation Risks —The Intersection of ERISA Section 510 and the Affordable Care Act’s...

The Affordable Care Act (ACA) is significantly changing employer health care obligations under the Employee Retirement Income Security Act (ERISA). Prior to ACA, the Supreme Court held that ERISA did not require employers to...more

Dickinson Wright

New Notice Requirements To Employees Regarding Health Insurance Exchanges And COBRA

Dickinson Wright on

All employers who employ one or more employees and are subject to the Fair Labor Standards Act (“FLSA”) must provide a new notice to employees no later than October 1, 2013 regarding the availability of health coverage under...more

Saul Ewing Arnstein & Lehr LLP

The Employer's Playbook for ACA Compliance: Are You In The 2014 "Pay Or Play" Game?

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

Shumaker, Loop & Kendrick, LLP

Strategic Implementation of Employer Shared Responsibility Rules & 2014 Planning Considerations

In This Presentation: •Welcome •Overview of the Employer Shared Responsibility Rules - Impact on Corporate Structure - Time Line Examples to Demonstrate Application of Measurement, Administrative & Stability...more

Davis Wright Tremaine LLP

The Obamacare “Play or Pay” Rules: A Practical Approach

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

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