Notices on Second Round of Privacy and Security Audits are Out, Expat Plans, OON Surgery Center Billing Issues, and New Nondiscrimination Rules for Federal Contractors, New ERISA Civil Monetary Penalties, COBRA Notices and...more
Expatriate health plans have been surprisingly difficult to reconcile with the Affordable Care Act (ACA). Proposed regulations set to take effect in 2017 provide some useful guidance to U.S. employers that sponsor expatriate...more
The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more
New guidance from the Internal Revenue Service (IRS) leaves in place the limited Affordable Care Act (ACA) exemptions set out in the Expatriate Health Coverage Clarification Act of 2014 (EHCCA). IRS Notice 2015-43 (Notice)...more
For expatriate health plans issued or renewed on or after July 1, 2015, the Expatriate Health Coverage Clarification Act of 2014 (EHCCA) provides an exemption from various Affordable Care Act (ACA) provisions. Last December,...more
In the Consolidated and Further Continuing Appropriations Act (the recently enacted federal budget bill often known as the “CRomnibus” legislation), Congress has exempted health plans designed to cover expatriates from most...more
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
As discussed in a prior post, the U.S. Internal Revenue Service (“IRS”) is currently in the process of finalizing its regulations implementing the Affordable Care Act’s (“ACA”) “Employer Mandate.” The Employer Mandate, which...more