News & Analysis as of

Cadillac Tax: A Levy in Limbo

The future of the Cadillac tax, a key cost-control mechanism and federal revenue source enacted as part of the Patient Protection and Affordable Care Act (ACA), is unclear. Though initially set to take effect in 2018,...more

New ACA, et. al. FAQs Cover Items From “Top” to “Bottom”

On April 20, the “Big Three” agencies (DOL, Treasury/IRS, and HHS) released another set of FAQs (the 31st, for those of you counting at home). Consistent with earlier FAQs, the new FAQs cover a broad range of items under the...more

A&B Healthcare Week in Review

I. REGULATIONS, NOTICES, & GUIDANCE - On April 15, 2016, the Food and Drug Administration (FDA) issued a proposed rule entitled, “Applications for Approval and Combinations of Active Ingredients Under Consideration for...more

ACA Reporting: IRS Deadline of March 31 Looms for Applicable Large Employers

Applicable large employers have new reporting requirements under the Affordable Care Act (ACA). Whether an employer is an applicable large employer is determined each calendar year by looking at the employer's workforce...more

New ACA Guidance Warrants Another "Checkup" of Employer Health Plans

On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....more

Employee Benefits Developments February 2016

IRS Issues Guidance Regarding Application of ACA Fee to Expatriate Health Plans. Section 9010 of the Affordable Care Act (ACA) imposes an annual fee on covered entities engaged in the business of providing health insurance...more

Student Health Plans and ACA Compliance: New Relief for Educational Institutions

Educational institutions face unique issues when complying with the requirements of the Affordable Care Act (ACA). One such issue relates to the administration of student health insurance plans. On February 5, 2016, three...more

If You Blinked You Might Have Missed Important Affordable Care Act Guidance

Notice 2015-87 issued by the IRS on December 16, 2015, provides guidance on numerous Affordable Care Act provisions. Below are some of the highlights....more

Agencies Confirm that Certain Student Health Insurance Subsidies for Student Employees May Violate the Affordable Care Act

Colleges and universities often offer to subsidize the cost of health coverage for student employees, either through the purchase of an individual health insurance policy or through a “premium reduction arrangement” designed...more

Health Coverage Providers: Deadlines for Health Coverage Providers to Report Minimum Essential Coverage are Approaching

Who Must Report? If you are a health insurance issuer, self-insured employer, or other entity that providedminimum essential coverage (MEC) during calendar year 2015, including a state government providing Medicaid or...more

The Affordable Care Act’s Reporting Electronic Backbone—The AIR System

For the last half of 2015, we spent a good deal of time explaining the Affordable Care Act reporting requirements that applied to carriers and large employers. This post examines the how of ACA reporting. In particular, it...more

ACA Reporting Deadlines Relaxed for 2016

Following complaints, concerns and continuing questions relating to the Affordable Care Act reporting requirements, the IRS has relaxed reporting deadlines for 2016 in the form of IRS Notice 2016-4. As you may be aware,...more

FAQs Regarding the ACA’s Employer Reporting Requirements (Part 1 of 2)

The employer reporting requirements under The Patient Protection and Affordable Care Act (the "ACA") are generally effective beginning January 1, 2015, with the applicable reports filed in early 2016. The purpose of the...more

Employee Benefits Developments - January 2016

IRS Guidance Addresses Numerous ACA Issues Related to HRAs. Just before the New Year, the IRS issued Notice 2015-87 (Notice), addressing the application of Affordable Care Act (ACA) market reform rules to different...more

Extension of ACA 2015 Reporting Deadlines Provides Welcome Relief for Employers

The Affordable Care Act (“ACA”) imposes various reporting requirements on insurers, self-insuring employers, and other providers of “minimum essential coverage" and imposes penalties on coverage providers that do not comply....more

Alert: Affordable Care Act Year-End Reporting Requirements and Extended Deadlines

This Alert serves as a reminder of certain Affordable Care Act ("ACA") year-end reporting requirements imposed under Sections 6055 and 6056 of the Internal Revenue Code of 1986, as amended (the "Code"). Section 6055 requires...more

IRS Issues New Guidance on ACA and Other Health Plan-Related Legal Requirements

In Notice 2015-87 the Internal Revenue Service (IRS) issued guidance on various health plan-related topics, including: (1) treatment of employer-provided opt-out payments for purposes of affordability under the Affordable...more

Congress Engages in Some Holiday Spending on Benefits

Congress’s recent $1.8 trillion holiday shopping spree (aka The Consolidated Appropriations Act, 2016, which became law on December 18, 2015) included a few employee benefit packages. We recently unwrapped the packages....more

ACA Reporting Deadline Is Welcome News To Employers

On December 28, 2015, the IRS announced in Notice 2016-4 that the deadlines for complying with the new reporting requirements under the Affordable Care Act (“ACA”) will be temporarily extended for purposes of 2015 coverage....more

Deadlines Extended on Cadillac Tax and ACA Forms 1095 and 1094 Reporting

In a recent Omnibus appropriations package, Congress extended the effective date for the Affordable Care Act (ACA) "Cadillac Tax" by two years, from plan years beginning on or after January 1, 2018, to plan years beginning on...more

Alert: Affordable Care Act (ACA) End of Year Checklist

With the Affordable Care Act (“ACA”) nearly fully implemented and agency enforcement now underway, employers must be clear which provisions of the ACA apply to them. Any employer that sponsors a health plan for employees is...more

FAQs Regarding the ACA’s Employer Reporting Requirements and Delay of Reporting Requirements

A few weeks ago, we provided the most Frequently Asked Questions regarding the employer reporting requirements under The Patient Protection and Affordable Care Act (the “ACA”), which are generally effective beginning January...more

IRS Extends 2015 Affordable Care Act Information Reporting Deadlines

In a welcome development for employers and health coverage providers, the IRS has extended the Affordable Care Act information reporting deadlines. Unlike the prior transition relief in which the IRS delayed the information...more

Employee Benefits Developments - December 2015

ALERT: IRS Extends ACA Reporting Deadlines. With only a few days remaining in 2015, the IRS provided some welcome relief for employers subject to certain Affordable Care Act reporting requirements. Under IRS Notice 2016-4,...more

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