If the U.S. Supreme Court rules that the federal Defense of Marriage Act (“DOMA”) is unconstitutional in Windsor v. U.S., which is expected to be decided this month, will employers that offer health benefits to employees’...more
On February 25, 2013, the Department of Health and Human Services (HHS) released its final rule (the Final Rule) setting forth standards for health insurance issuers under the Patient Protection and Affordable Care Act (the...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
It was open enrollment for health benefits at Nossaman last week, and the conference room was filled with employees waiting to be briefed. Having spent the better part of the last few years of my professional life being...more
In This Issue: Exchanges and Types of Plans To Be Offered Through Exchanges; Essential Health Benefits; Premiums; Cost Sharing Reductions; and Other Issues. Excerpt from Exchanges and Types of Plans To Be...more
Beginning in 2014, the employer shared responsibility mandate of the Patient Protection and Affordable Care Act requires applicable large employers (those employing on average at least 50 full-time equivalent employees on...more
Essential Health Benefits - On February 20, 2013, the U.S. Department of Health and Human Services (HHS) issued a final rule that set the accreditation standards for qualified health plans (QHPs)—plans that will be...more
The Department of Health and Human Services issued final regulations on the Affordable Care Act’s standards for essential health benefits, actuarial value, and accreditation. While these regulations primarily affect...more
In This Issue: - Minimum Essential Coverage ..HHS Proposed Rule - Shared Responsibility Payments and Exemptions ..HHS Proposed Rule ..IRS Proposed Rule ..IRS Final Rule - Essential Health Benefits ...more
The U.S. Department of Health and Human Services (HHS) Essential Health Benefits Final Rule and actuarial value regulations offer few surprises and much needed certainty to enable group health plans and health insurance...more
As Washington and the rest of the country brace for cuts from the sequester to kick in on March 1, Florida Gov. Rick Scott surprised many and confirmed others' predictions by announcing his state will expand its Medical...more
In This Issue: Implementation of the Affordable Care Act; Other HHS and Federal Regulatory Initiatives; Other Congressional and State Initiatives; Other Health Care News; and Hearings and Mark-Ups Scheduled. Excerpt...more
On February 20, 2013, the Department of Health and Human Services (HHS) released a final rule under the Affordable Care Act (ACA) that will allow insurers and states to forge ahead with both federal and state health...more
The U.S. Department of Health and Human Services has issued final regulations and a set of frequently asked questions and answers establishing standards for the provision of essential health benefits in the individual and...more
Beginning in 2014, all non-grandfathered health insurance coverage in the individual and small group markets, Medicaid benchmark and benchmark-equivalent plans, and Basic Health Programs (if applicable) must cover essential...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
As a reminder of the significant role that states will play in implementing the provisions of the Affordable Care Act (ACA), we wanted to highlight some recent legislative developments in California that will be of interest...more
Under the Affordable Care Act (“ACA”), a large employer is subject to penalties if it fails to offer to full-time employees and their dependents health coverage or if the coverage that it offers is not affordable or does not...more
In the past week, the Congressional Budget Office (CBO) released an updated federal budget to account for new regulations from the Department of Health and Human Services (HHS) and the Internal Revenue Service (IRS),...more
As 2014 rapidly approaches, employers of all sizes and all industries are working hard to avoid the Affordable Care Act’s (the “Act”) Employer Mandate, now appearing in the Internal Revenue Code, Section 4980H. For employers...more
The IRS and the U.S. Department of Health and Human Services (HHS) have issued two important pieces of guidance under the Patient Protection and Affordable Care Act regarding the responsibilities imposed on individuals to...more
In early January, the Internal Revenue Service published proposed regulations on “Shared Responsibility for Employers Regarding Health Coverage.” These regulations incorporate the provisions of many previous Notices with...more
The countdown to the 2014 implementation of the Affordable Care Act (ACA) has begun. Each week, administrative decisions, guidance, rules and regulations are coming from the federal and state governments to make ACA a...more
The U.S. Treasury Department recently released new guidance to assist employers (generally those with 50 or more full-time or full-time equivalent employees) in preparing and planning for the 2014 requirement to offer...more
On November 20, 2012, the Department of Health and Human Services (HHS) issued proposed rules under the Patient Protection and Affordable Care Act of 2010, as amended (the Affordable Care Act or the Act), which beginning in...more
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