Employer Mandates Patient Protection and Affordable Care Act (PPACA) Internal Revenue Service

Employer Mandates is a term commonly used to describe employer insurance obligations under the Affordable Care Act. Under the Affordable Care Act, employers with 50 or more employees are required to provide... more +
Employer Mandates is a term commonly used to describe employer insurance obligations under the Affordable Care Act. Under the Affordable Care Act, employers with 50 or more employees are required to provide minimum essential insurance coverage to their employees or else pay statutory penalties. The concept of an employer mandate is not unique to the Affordable Care Act; many EU countries have their own versions with different and/or expanded employer obligations.  less -
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The Affordable Care Act—Countdown to Compliance for Employers, Week 1: Going Live with the Affordable Care Act’s Employer Shared...

Regulations implementing the Affordable Care Act’s (ACA) employer shared responsibility rules including the substantive “pay-or-play” rules and the accompanying reporting rules were adopted in February. Regulations...more

ACA Outlook: What Will 2015 Hold for the Affordable Care Act and Employers?

For many employers, the effective date of the Affordable Care Act's "play-or-pay" mandate is only weeks away. The impending deadline comes amid questions about the future—and perhaps viability—of the law itself. Entering...more

Health Care Reform Implementation Update

We are now more than two weeks into the Affordable Care Act (ACA’s) second open enrollment period, and 765,000 individuals have obtained coverage through HealthCare.gov. On Capitol Hill, House lawmakers filed a lawsuit...more

Determining Full-Time Employee Status for ACA: IRS Issues Guidance for Changes in Measurement or Methods

The employer shared responsibility provisions (commonly referred to as the "pay-or-play" mandate) of the Affordable Care Act ("ACA") impose penalties on applicable large employers that fail to offer qualifying health coverage...more

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

New ACA Guidance Permits Employer-Initiated Measurement Period Changes

The Internal Revenue Service (IRS) recently released Affordable Care Act (ACA) guidance addressing how to determine full-time status when an employee’s measurement period changes. The guidance, IRS Notice 2014-49, introduces...more

Alert: Closing Affordable Care Act Loopholes

The U.S. Departments of Labor, the Internal Revenue Service and the Department of Health and Human Services recently issued guidance clearly stating that employers may not, without incurring penalties, reimburse employees who...more

Don't Forget! Preparing for the Affordable Care Act Employer Mandate

With 2015 just a few weeks away, employers with 100 or more full-time and full-time equivalent employees should be gearing up for the implementation of the Affordable Care Act (“ACA”) employer mandate, which subjects...more

Manatt on Health Reform: Weekly Highlights: November 2014 #2

With the conclusion of the midterm elections last week and open enrollment just around the corner, this week’s news highlights both renewed pledges from the opposition and a flurry of implementation activity in the states....more

The Affordable Care Act—Countdown to Compliance for Employers, Week 6: Labor and Treasury Departments Play Whack-a-Mole with...

Last year, the Department of Labor and the Treasury Department/IRS (Departments) issued guidance on the application of certain of the Affordable Care Act’s insurance market reforms to health reimbursement arrangements (HRAs),...more

Supreme Court Will Decide Whether Citizens in NC and 26 Other States Can Receive Tax Credits for Health Care Premiums!!

With a decision that, I can only imagine, ricocheted against the White House walls, the Supreme Court granted certiorari to hear King v. Burwell this past Friday, November 7, 2014, despite Obama’s administration’s request for...more

U.S. Supreme Court Agrees to Hear Arguments Involving Federal Health Insurance Exchange Subsidies

On Friday, the U.S. Supreme Court announced that it would review the U.S. Court of Appeals for the Fourth Circuit’s decision in King v. Burwell. In that case, the Fourth Circuit held that tax credits for health insurance...more

Feds Tighten the Belt on "Skinny Plans" and Other ACA Workarounds

On January 1, 2015, employers with 100 or more "full-time equivalents" will be subject to the "Pay or Play" regulations under the Affordable Care Act ("ACA"). Over the past few years, many consultants have sought to identify...more

New Agency FAQs Drive a Stake Further into the Heart of Premium Reimbursement Arrangements and Eliminate a Common Executive Perk

In clear and unambiguous terms, the U.S. Departments of Labor (“DOL”) and Health and Human Services and the Internal Revenue Service (“IRS”) (the “Agencies”) drove a stake into the heart of two suspect health insurance...more

IRS to Close “Loophole” on “Sub-Standard” Plans without Hospitalization or Physician Services Coverage

On November 4, 2014, the Internal Revenue Service (“IRS”) announced that it intends to close a perceived “loophole” in health care reform. This so-called loophole allows employers to offer low cost health plans that don’t...more

IRS Seeks to Curb Popularity of ‘Skinny’ Health Plans

The Internal Revenue Service, in Notice 2014-69, has concluded that certain unconventional group health plan designs that offer limited or no coverage for in-patient hospitalization services and/or physician services will not...more

Affordable Care Act Update: Hospitalization Services Required for Plan to Meet Minimum Value

On November 4, 2014, the Internal Revenue Service (IRS) released guidance (Notice 2014-69) clarifying that certain group health plans that do not provide for hospitalization services or physician services or both will fail to...more

New IRS Guidance May Require Amendments to Section 125 (“Cafeteria”) Plans

Many employers permit employees to pay for employer-sponsored health coverage, on a pre-tax basis, under Internal Revenue Code section 125 (“cafeteria”) plans. These plans generally require employees to make an irrevocable...more

Section 6055 Reporting of Health Plan “Minimum Essential Coverage” for Small and Large Employers

Starting in 2016, Section 6055 of the Internal Revenue Code, which was added by the Health Care Reform Act, requires all entities providing “minimum essential coverage” (MEC) to submit information to the IRS concerning each...more

Proposed Approach for Applying the “Look-Back” Method When the Section 4980H Measurement Period Changes

The Internal Revenue Service (IRS) recently issued Notice 2014-49 which describes a proposed approach for determining an employee’s full-time or part-time status for purposes of the employer shared responsibility rules under...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 11: Rethinking ACA Compliance Strategies Involving Reference...

Under the Affordable Care Act’s rules governing employer shared responsibility—which are codified in Internal Revenue Code § 4980H—where an applicable large employer makes an offer of group health plan coverage that is both...more

Health Plan ID Requirements and Other End-of-Year Considerations

Employers and other health plan sponsors may be focused on preparing for the commencement of the employer mandate under the Affordable Care Act on January 1, 2015, but a number of other deadlines and developments are emerging...more

New Developments and Impending Deadlines for Employer Group Health Plans

As the federal government agencies continue to push forward with implementation and administration of health care reform (i.e., the Patient Protection and Affordable Care Act), there are two recent developments that we want...more

IRS Issues New Forms And Instructions Regarding The Employer Mandate Information Reporting Requirements Under The ACA

In order to administer and enforce the rules of the Employer Shared Responsibility Mandate, the Affordable Care Act (ACA) added Sections 6055 and 6056 to the Internal Revenue Code, which require insurance providers and...more

Monthly Benefits Update - September 2014

IRS Issues Guidance on How to Deal With a Change to an Employee’s Measurement Period Under ACA Employer Mandate - The Internal Revenue Service (IRS) issued Notice 2014-49, which proposes an approach for dealing with...more

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