News & Analysis as of September 19, 2024

Reporting Requirements

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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 -

Compliance Alert: IRS Proposes Permanent 30-day Extension to ACA Reporting Deadline

Woodruff Sawyer on 12/6/2021

Insights December 3, 2021 /Employee Benefits On November 22, 2021, the IRS filed a Notice of Proposed Rulemaking (“Proposed Rule”) that among other things, provides for an automatic 30-day extension of the deadline for...more

IRS Says ACA’s Employer Mandate is a Forever Liability – What Should Large Employers Do Now?

Foley & Lardner LLP on 3/19/2020

Takeaway Message: The IRS has recently concluded that the Affordable Care Act’s (the “ACA”) employer mandate is an ongoing tax liability which cannot be extinguished with the passage of time. In other words, the IRS has no...more

IRS Memo Concludes No There Is Statute of Limitations for ACA Employer Mandate Penalties Under Internal Revenue Code § 4980H

Epstein Becker & Green on 3/9/2020

The IRS Office of Chief Counsel recently issued a memo which, in a surprise to many, concluded that the filing of the Affordable Care Act (“ACA”) Forms 1094-C and 1095-C (“C Forms”) does not start the statute of limitations...more

Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row

Burr & Forman on 12/16/2019

Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is necessary in order for the IRS to administer certain portions of...more

IRS Extends ACA Reporting Deadline and Issues Transition Relief

Proskauer - Employee Benefits & Executive... on 12/3/2019

The IRS has not yet finalized the ACA reporting forms (i.e., the 1094-B/C and 1095-B/C) for the 2019 tax year, so it is no surprise that the IRS issued guidance this week extending the deadline to furnish the forms to...more

Good News on Health Coverage Reporting for 2018 Coverage

Winstead PC on 11/30/2018

Normally, the deadline for reporting health care coverage by a self-insured medical plan or an insured plan follow rapidly after year end. In an early holiday gift, the Internal Revenue Service (the “Service”) provided an...more

Massachusetts Health Insurance Responsibility Disclosure Form Must Be Filed by November 30 and Annually Thereafter

Proskauer - Employee Benefits & Executive... on 11/29/2018

Massachusetts recently published guidance regarding its new Health Insurance Responsibility Disclosure (HIRD) annual filing, which is due for the first time on November 30, 2018 and then annually thereafter. This new HIRD...more

A Game Plan for Employers Facing Possible ACA Penalties

Carlton Fields on 1/18/2018

All employers are at risk of receiving a notice from the IRS that they are liable for a penalty under the Affordable Care Act for failing to offer enough employees insurance coverage, or for failing to offer particular...more

Massachusetts to (Again) Require Health Care Reporting by Employers

Mintz - Employment Viewpoints on 1/17/2018

Massachusetts employers with 6 or more employees will soon be required to prepare and file a new health care reporting form referred to as the “healthcare coverage form.” While reminiscent of the now repealed “Health...more

Brace for Impact: IRS Says ACA Employer Mandate Penalties Coming

Fisher Phillips on 11/30/2017

The IRS quietly revised its FAQ on employer shared responsibility provisions under the Affordable Care Act (ACA) in November, adding a bombshell statement that it plans to inform employers of their “potential liability for an...more

IRS Begins Issuing ACA Employer Mandate Penalty Notices

Stinson - Benefits Notes Blog on 11/27/2017

Recently, the Internal Revenue Service (IRS) indicated that it would begin enforcing the Affordable Care Act (ACA) Employer Shared Responsibility provisions (commonly known as the “Employer Mandate”). Last week, the IRS...more

Health Care Reform Roundup – Issue 9

Proskauer - Employee Benefits & Executive... on 9/7/2017

After health care reform efforts failed in late-Spring/early-Summer, things have been quiet. However, Congress returned to DC this week. Although legislative focus now appears to be on general tax reform, we expect some...more

Updated Health Care Reform Legislation Comparison Chart

Proskauer - Employee Benefits & Executive... on 7/15/2017

The chart below compares key provisions of the Affordable Care Act (ACA), the American Health Care Act (AHCA) and the Better Care Reconciliation Act (BCRA). This chart is current as of July 13, 2017, and as of that date,...more

American Health Care Act – Key Takeaways for Employers and Plan Sponsors

Proskauer - Employee Benefits & Executive... on 3/9/2017

On March 6, 2017, the House of Representatives’ Ways and Means Committee and Energy and Commerce Committee released budget reconciliation recommendations that will, after mark-up beginning on March 8th, form the American...more

Issue 95: Health Care Reform Reporting Is Coming: Is Your Company Prepared?

Seyfarth Shaw LLP on 11/11/2015

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

Navigating Legal Issues in Connection with Employer Sponsored On-Site Health Clinics

McDermott Will & Emery on 10/13/2015

Employers are increasingly concerned with the high cost of health care and executives in the C-Suite are beginning to take notice. The Affordable Care Act (‘‘ACA’’) required employers who sponsor group health plans to adopt a...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 9 of 24): Unraveling the Mystery of Indicator...

Mintz - Employment, Labor & Benefits... on 9/15/2015

The Affordable Care Act’s reporting rules—which are set out in Internal Revenue Code §§ 6055 and 6056—solicit the information needed by the Internal Revenue Service to enforce the individual and employer shared responsibility...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 6 of 24): Reporting Group Health Plan Opt-Out...

Mintz - Employment, Labor & Benefits... on 8/25/2015

Under a common strategy for controlling group health care plan costs, employers sometimes adopt arrangements under which an employee is offered cash as an incentive to waive coverage. These arrangements are colloquially...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 5 of 24): Reporting of Health Reimbursement...

Mintz - Employment, Labor & Benefits... on 8/19/2015

As we reported last week, the IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C. These instructions are of interest to applicable large employers who must report their compliance with the Affordable Care...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 2 of 24): Yikes! The Costs of Failing to Comply...

Mintz - Employment, Labor & Benefits... on 7/27/2015

The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...more

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Employer Mandates › Employer Group Health Plans › Reporting Requirements

Compliance Alert: IRS Proposes Permanent 30-day Extension to ACA Reporting Deadline

IRS Says ACA’s Employer Mandate is a Forever Liability – What Should Large Employers Do Now?

IRS Memo Concludes No There Is Statute of Limitations for ACA Employer Mandate Penalties Under Internal Revenue Code § 4980H

Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row

IRS Extends ACA Reporting Deadline and Issues Transition Relief

Good News on Health Coverage Reporting for 2018 Coverage

Massachusetts Health Insurance Responsibility Disclosure Form Must Be Filed by November 30 and Annually Thereafter

A Game Plan for Employers Facing Possible ACA Penalties

Massachusetts to (Again) Require Health Care Reporting by Employers

Brace for Impact: IRS Says ACA Employer Mandate Penalties Coming

IRS Begins Issuing ACA Employer Mandate Penalty Notices

Health Care Reform Roundup – Issue 9

Updated Health Care Reform Legislation Comparison Chart

American Health Care Act – Key Takeaways for Employers and Plan Sponsors

Issue 95: Health Care Reform Reporting Is Coming: Is Your Company Prepared?

Navigating Legal Issues in Connection with Employer Sponsored On-Site Health Clinics

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 9 of 24): Unraveling the Mystery of Indicator...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 6 of 24): Reporting Group Health Plan Opt-Out...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 5 of 24): Reporting of Health Reimbursement...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 2 of 24): Yikes! The Costs of Failing to Comply...

Simple ACA Rules for Simple (But Not Small) Employers

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 1 of 24)

IRS Releases Final Forms and Instructions for Affordable Care Act Reporting

ACA Issues for Employers to Stay Aware of in 2015

IRS Publishes Final Forms and Instructions on Information Reporting Under the Affordable Care Act

Employer Mandates › Employer Group Health Plans › Reporting Requirements

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