Employer Mandates Internal Revenue Service Healthcare Reform

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 -
News & Analysis as of

IRS Grants Extension of ACA Information Reporting Deadline and Provides Good Faith Standards for 2016 Information Reports

The IRS recently issued Notice 2016-70, which extends certain 2017 deadlines for employer information reporting under the Affordable Care Act (ACA) on health coverage offered to individuals during the 2016 calendar year. The...more

Employee Benefits Developments - November 2016

The Employee Benefits practice group is pleased to present the Benefits Developments Newsletter for the month of November, 2016. ACA Information Reporting – Bad News and Good News - First, the bad news: The 2016 final...more

Update on ACA Reporting (Forms 1095-C and 1094-C) – Round Two

The Internal Revenue Service just issued Notice 2016-70 granting certain transitional relief in regards to 2016 ACA reporting requirements. In particular this Notice: - Postpones the due date to provide 2016 Form...more

Will Employers’ ACA Obligations Change Under the Trump Administration?

During his campaign, President-elect Trump promised to make the repeal and replacement of the Affordable Care Act (ACA) a priority. Now that the election is over, what should employers expect? We don’t have a crystal ball,...more

Affordable Care Act – Compliance with the Updated Health Care Coverage Forms

The IRS recently released new Forms 1094-C and 1095-C for 2016 employer reporting of health coverage. It is imperative that employers review these new forms as numerous changes have been made to clarify previously unclear...more

Hot Topics in Employer Health Benefits

As we start looking forward to 2017, and as many employers head into annual enrollment periods this fall, employers need to be aware of recent changes in the law that have a significant impact on health benefit plans. This...more

IRS Addresses Health Coverage Opt-Out Payments Under the Affordable Care Act

As the cost of providing health coverage increased over the past fifteen years, many employers began to offer employees cash payments if they “opted out” of coverage. Some expected that the Affordable Care Act (ACA) would...more

Reporting for ACA Mandates: Final Forms and Additional Guidance

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...more

Health Care Reform - It’s time for employers to roll up their sleeves in 2015.

This year promises to be a big year for health care reform. The controversial employer mandate, delayed one year for larger firms, took effect on January 1. The IRS announced transition rules for those employers to ease the...more

EAPs That Meet Four Requirements May Avoid Application of Health Care Reform

Benefits provided through an employee assistance program (“EAP”) may be considered group health plan coverage, which would subject the EAP to the health care reform requirements mandated by HIPAA and the Health Care Reform...more

Your New Year’s Resolutions Should Include Affordable Care Act Compliance

Since its enactment more than four years ago, the Affordable Care Act (ACA) has made several significant changes to health care. Provisions implemented in 2014 included state and federal exchanges, health insurance premium...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

Health Care Reform Implementation Update

Congress is in recess and therefore much of the action surrounding the Affordable Care Act (ACA) is at the agency level. However, Congressman Darrel Issa (R-CA) did subpoena the U.S. Department of Treasury for their records...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 16: So What, Exactly, is an “Offer of Coverage”?

Whether an employer makes the requisite offer of group health plan coverage is critical to the application of the Affordable Care Act’s employer shared responsibility rules as reflected in final implementing regulations...more

IRS Issues Draft Forms for Coverage Reporting Requirements under the Affordable Care Act

The Internal Revenue Service (IRS) has released draft versions of forms that will be used by employers to report health coverage information required under the ACA’s employer shared responsibility rules. As we have written in...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 22: Charting the Future of the Premium Subsidies (and Employer...

On July 22, 2014, two federal appellate courts issued conflicting decisions, within hours of each other, regarding the IRS final rule published on May 23, 2012 (the “IRS Rule”), intended to implement the exchange-related tax...more

Of Mice and Elephants: Halbig and King and The Struggle of Two Federal Appeals Courts to Find Meaning in Words That May or May Not...

At issue in Halbig v. Burwell and King v. Burwell is whether or not subsidies to buy insurance on an exchange are available in both state and federal exchanges. On its face the Affordable Care Act (“ACA”) provides for...more

Federal Appeals Court in D.C. Strikes Down Key Aspect of Health Care Reform (Just Before the 4th Circuit’s Opposite Ruling) – Any...

On Tuesday, the U.S. Court of Appeals for the District of Columbia Circuit, in a 2-1 ruling by a three judge panel, invalidated an Internal Revenue Service regulation that interpreted section 36B of the Affordable Care Act...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 26: Fitting a Round Peg (the Public Health Service Act 90-day...

The Departments of the Treasury/IRS, Labor and Health and Human Services (the “Departments”) recently issued a final regulation under the 90-day waiting period limitation, which is included among the Affordable Care Act’s...more

Health care reform reporting requirements: Final rules

The Patient Protection and Affordable Care Act (PPACA) contains requirements for both individuals and employers related to health care coverage. In order to assure compliance with certain of these requirements, PPACA requires...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 31: ERISA Section 510 and Limiting Employee Hours

In last week’s post, we examined the appropriateness of capping the annual hours of new “variable hour employees” as a way to limit exposure under the Affordable Care Act’s employer shared responsibility rules. (These rules...more

What Does PPACA Stand For? Punitive Penalties Are Clearly Authorized

A recently posted IRS Q&A raises the specter of serious penalties for non-compliance with the Affordable Care Act. The context of the question relates to the consequences to employers that do not establish a health insurance...more

Health Care Reform: Who is a Full-Time Employee?

Determining who is a full-time employee is an essential task under health care reform’s employer mandate, which generally imposes significant penalties on large employers who fail to offer their full-time employees affordable...more

Monthly Benefits Update - February 2014

Health & Welfare Plans - Health Care Reform: IRS Issues Final ACA “Pay or Play” Regulations - The IRS issued final regulations regarding the employer shared responsibility provisions under the Affordable Care...more

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