News & Analysis as of

Obama Administration Finalizes Health Insurance Wraparound Coverage Rule

The Departments of Labor, Health and Human Services, and Treasury published a final rule on March 18, 2015 that amends the definition of excepted benefits to allow group health plan sponsors, in limited circumstances, to...more

BEST IN LAW: Employers need to heed Obamacare Reporting Rules

Compliance with reporting obligations is always important for any employer, but the employer reporting requirements under the Affordable Care Act pack a significant penalty that makes compliance particularly...more

New HHS Regulations “Clarify” that Health Plans Covering Families Must Have “Embedded” Individual Cost-Sharing Limits

On February 27, 2015, the Department of Health and Human Services (HHS) released its final HHS Notice of Benefit and Payment Parameters for 2016. The lengthy regulation covers a wide range of topics affecting group health...more

Short-Term Relief for Small Employers Reimbursing Employee Premiums - But Significant Penalties Loom if You Don’t Stop Soon!

For nearly two years now, the IRS has been explaining that employers are no longer permitted to reimburse employees for premiums the employees paid for individual health insurance coverage....more

IRS Provides Temporary Enforcement Relief for Small Employers Offering Employer Payment Plans

The IRS issued guidance providing enforcement relief through June 30, 2015 for small employers who offer employer payment plans to their employees. In the guidance, the IRS reiterated its stance that an employer payment...more

IRS Releases Preliminary Guidance on “Cadillac Plan” Tax under ACA

The IRS released Notice 2015-16, which represents the first piece of guidance issued by a regulatory agency on the excise tax on high cost employer-sponsored health coverage, colloquially known as the “Cadillac plan” tax. The...more

Final IRS Forms and Instructions for Reporting Health Coverage Clarify Large Employer Requirements for 2015 and Beyond

On February 8, 2015, the IRS released final forms and instructions for reporting health coverage pursuant to Code Sections 6055 and 6056, which were added by the Health Care Reform Act. As stated below, large employers and...more

Monthly Benefits Alert - February 2015

Health & Wellness Plans - Anthem Data Breach Requires Plan Sponsor Attention - On January 29, 2015, Anthem Inc., one of the largest managed health care companies in the country, disclosed that the sensitive...more

Has the Supreme Court Given Advance Notice How It Will Decide King v. Burwell?

On Wednesday, March 4, 2015, the Supreme Court will hear argument in King v. Burwell, the most publicized case in some time. Most readers are aware that the issue is whether certain tax subsidies essential to the proper...more

Could a Cadillac Health Plan Put the Brakes on Obamacare?

The Supreme Court is hearing oral arguments Wednesday, March 4 on certain aspects of the Affordable Care Act. This has the potential to unravel President Barack Obama’s beloved health care plan. Another aspect of...more

Permissible Discrimination in Health Benefits

The intense regulation of health care benefits, especially with respect to the Affordable Care Act, has created much confusion among employers. As a result, many employers do not understand that they may offer different...more

Five Health Care Developments Important to Employers

Perhaps never before have employers faced so many challenges when it comes to health care issues affecting their workforce. Congress may try to amend the Affordable Care Act (“ACA”). The Supreme Court of the United States is...more

Premium Reimbursement Arrangements Get Relief - More ACA Transition Relief—This Time for Small Employers and S-Corps

The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more

Partial Relief for Employer Payment of Individual Insurance Premiums

In a recent notice, the Internal Revenue Service has tempered prior guidance that closed the door on employer arrangements for paying the cost of individual health insurance for employees. The IRS still views these premium...more

ACA Countdown to Compliance - 52 Week Series For Employers

In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more

Beware of Stop-Loss Coverage Gaps When Choosing a Self-Funded Major Medical Plan

The Affordable Care Act requires applicable large employers to make broad-based offers of group health insurance coverage to substantially all their full-time employees or face potential tax penalties. (The term “applicable...more

IRS Clarifies Prior Guidance on Premium Reimbursement Arrangements; Provides Limited Relief

Continuing its focus on so-called “premium reimbursement” or “employer payment plans”, the Internal Revenue Service (IRS) released IRS Notice 2015-17 on February 18, 2015. In this Notice, which was previewed and approved by...more

ACA Issues for Employers to Stay Aware of in 2015

With the Affordable Care Act's Employer Mandate (Pay-or-Play penalties) now officially in effect, employers with 50 or more full-time or full-time-equivalent employees should have already made all significant changes to their...more

Eligibility Rules Need To Be In Writing

Healthcare reform continues to roll on. 2014 saw the implementation of the health insurance exchanges, the Individual Mandate, and a host of new rules relating to employer-provided health coverage. 2015 marks the start of yet...more

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

The Internal Revenue Service (IRS) published final forms and instructions addressing information reporting requirements applicable to employers and insurers under Internal Revenue Code Sections 6055 and 6056. The reporting...more

IRS Finalizes Forms and Instructions for ACA Information-Reporting Requirements

For the 2015 calendar year, the Patient Protection and Affordable Care Act of 2010 (“ACA”) imposes information-reporting requirements on health insurance issuers and employers. Insurers and employers are required to report to...more

Manatt on Health Reform: Weekly Highlights - February 2015 #2

HHS ramps up for the final week of open enrollment. Families buying into CHIP in Pennsylvania are granted tax relief, and though Medicaid expansion efforts seem to have hit a wall in Tennessee and Wyoming, Arkansas assures...more

Top 10 Topics for Directors in 2015: Explore New Trends in Reducing Corporate Health Care Costs

The increasing cost of healthcare is a significant concern for companies that provide health care benefits to their employees. With certain key provisions of the Patient Protection and Affordable Care Act, more commonly known...more

Congress Clarifies the Expatriate Health Coverage Exemption

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

Agencies Green Light Pilot Program to Allow Limited Wrap-Around Coverage for Health Insurance Policies Purchased on an Exchange

Under proposed rules recently issued by the Departments of Treasury, Labor, and HHS, employers may participate in a pilot program where they offer certain wraparound coverage as an “excepted benefit” to part-time employees,...more

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