News & Analysis as of

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

New Proposed Rules Streamline ACA Summary of Benefits and Coverage (SBC) Disclosure Requirement

In a very welcome development for health insurance issuers and employers who sponsor self-funded group health plans, the Departments of Treasury, Labor, and HHS have issued joint new proposed regulations that will streamline...more

2015 Health Care Reform Compliance Checklist for Employers

The United States has entered a new era of health care reform. Until now, United States employers were generally not required to provide health care coverage to employees (although many did so for employee relations and...more

Caution: Big Penalties for Reimbursing Health Care Premiums

Even if you are a small employer who is not required to provide your employees with health insurance under the Affordable Care Act (ACA), if you reimburse your employees for health insurance premiums, you run the risk of...more

Administration Issues Proposed Rules on ACA Summary of Benefits and Coverage, Excepted Benefits/Wraparound Coverage

On December 30, 2014, the Internal Revenue Service (IRS), the Employee Benefits Security Administration (EBSA), and the Centers for Medicare & Medicaid Services (CMS) published a proposed rule that would revise Affordable...more

Health Headlines: Also in the News - January 2015 #2

House Passes Bill to Redefine Full-Time Employee Under ACA – On January 8, 2015, the House of Representatives in a 252-172 vote approved a bill that would redefine a full-time worker under the ACA employer mandate from one...more

Employing Veterans May Help Avoid the ACA’s Employer Mandate

The new Republican Congress began its session with an attempt to narrow the Affordable Care Act’s (ACA) employer mandate by exempting certain veterans and their families from counting toward the number of employees at small...more

A Quick Look at Healthcare Issues Expected to Make News in 2015

As we look into our crystal balls, we do not expect a lot of new issues in 2015. Rather, we believe that most of the significant issues will be a continuation of issues that arose in 2014 or earlier. ...more

Distant Cousins, not Twins: Some Key Differences between the Massachusetts and Federal Health Care Reform Laws

On January 1, 2015, the Affordable Care Act’s (ACA) employer shared responsibility mandate took effect. Up until July 1, 2013, most employers doing business in Massachusetts were required to comply with an employer mandate...more

Excepted Benefits: Final regulations provide guidance on dental, vision and employee assistance plans

The Departments of Labor, the Treasury, and Health and Human Services (the “Departments”) have recently published final regulations related to when limited scope dental and vision benefits and employee assistance programs...more

No Pre-Existing Condition Exclusions Means HIPAA Certificates No Longer Required

Earlier this year, the Departments of Health and Human Services, Labor and the Treasury issued a final rule implementing the Affordable Care Act (ACA) and revising the requirements of other healthcare laws and regulations...more

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