News & Analysis as of

Implementation Date for New Summary of Benefits and Coverage Template

The U.S. Departments of Treasury, Labor, and Health and Human Services (the Departments) recently issued new guidance regarding the intended timeframe for the use of the new summary of benefits and coverage (SBC) template and...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

DOL Issues Proposed Updates for Summaries of Benefits and Coverage

The U.S. Department of Labor (DOL) has issued an updated template Summary of Benefits and Coverage (SBC), Glossary of Coverage and Medical Terms, and related materials. The revised materials remain in proposed form, but have...more

Issue 99: Transition Relief for Student Health Plans and Other ACA Issues Impacting Student Employees

This is the ninety-ninth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...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

Cadillac Tax Effective Date Postponed (and Three Other 2015 Year End Health and Welfare Benefits Legislation Highlights)

While Americans everywhere were busy eating turkey and drinking eggnog last November and December, our government was hard at work attending to budget matters. Tucked among the appropriations were several fairly significant...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

Issue 96: Happy Holidays - Cadillac Tax is Delayed!

This is the ninety-sixth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

IRS Notice 2015-87 (Part 1) – IRS Issues New HRA Integration Rules

On December 16, 2015, the Internal Revenue Service issued Notice 2015-87 containing guidance on a wide-range of topics under the Affordable Care Act (ACA). In addition to providing guidance on affordability and COBRA matters...more

IREG Update - December 2015 #2

Delaying the Cadillac tax: The story of a successful coalition of strange bedfellows - Congress has rarely found bipartisan agreement on anything relating to the Affordable Care Act (ACA). However this week they are...more

Health Care Reform - Departments Issue Final Rules Under ACA

Last month, the Departments of the Treasury, Labor and Health and Human Services issued final regulations governing several market reforms implemented under the Affordable Care Act. These regulations finalize the 2010 interim...more

Don’t Forget to Amend Cafeteria Plan for New Permitted Election Change Events

In 2014, the Internal Revenue Service (IRS) expanded the events that would allow employees to drop their health plan coverage under their employer’s cafeteria plan. As a reminder, the general rule is that once an employee...more

It’s health insurance open enrollment — research, choose carefully

November has become more than the month devoted to families and feasting: It’s now the start of the season when Americans try like heck to avoid becoming health insurance turkeys. Open enrollment periods are under way — for...more

ACA Reporting 101

One of the new Affordable Care Act (ACA) requirements imposed on employers is the obligation to report employee group health plan coverage information to the IRS and employees on Forms 1094-C and 1095-C. The first required...more

New FAQs on Preventive Services, Wellness Program Rewards and Mental Health and Substance Use Treatment: McGuireWoods Healthcare...

This is the 54th in a series of WorkCite articles concerning the Patient Protection and Affordable Care Act and its companion statute, the Health Care and Education Reconciliation Act of 2010 (referred to collectively as the...more

New Affordable Care Act FAQs Provide Guidance on Preventive Services, Wellness Programs and Mental Health Parity

On October 23, 2015, the Departments of Labor, Health and Human Services and Treasury (the “Agencies”) jointly released their twenty-ninth (XXIX) set of Frequently Asked Questions (FAQs) about Affordable Care Act (ACA)...more

Recent Government-Issued FAQs Cause Plan Sponsors to Clarify Preventive Care and Wellness in Health Plan Communications

On October 23, 2015, the U.S. Departments of Labor (DOL), Health and Human Services (HHS), and Treasury issued frequently asked questions (FAQs) on the implementation of preventive care and wellness provisions of the...more

ACA Automatic Enrollment Mandate Repealed by Bipartisan Budget Act

On Monday, November 2nd, the President signed the Bipartisan Budget Act of 2015 (BBA). Some legislators had hoped that a budget deal would at least include a repeal of the controversial 40% excise tax on high-cost health...more

Benefits Fast Facts

PACE Act: Some Positive News For Employers With 51 To 99 Employees - For insurance market reform purposes, the Affordable Care Act (ACA) initially defined “small employers” as those with fewer than 50 employees. This...more

Automatic Enrollment for Health Plans Has Been Repealed

Budget legislation signed into law by President Barack Obama on November 2, 2015, the Bipartisan Budget Act of 2015, repeals the controversial automatic enrollment provision under the Affordable Care Act (ACA). Section 18A of...more

Employee Benefits Developments - October 2015

The Internal Revenue Service (IRS), consistent with prior regulations from the Department of Health and Human Resources (HHS), issued supplemental proposed regulations requiring employer sponsored health plans to provide...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

New Affordable Care Act FAQs Issued

On October 23, the U.S. Department of Labor, the Department of Health and Human Services, and the Department of the Treasury (collectively, the “Departments”) jointly issued answers to frequently asked questions regarding the...more

Washington Healthcare Update

Bicameral Bill Introduced to Provide HHS Authority to Reject Proposed Insurance Rates - Before Congress left for its Columbus Day recess, Rep. Jan Schakowsky (D-IL) and Sen. Diane Feinstein (D-CA) introduced the Health...more

President Obama Signs ACA Change Into Law

While Republican efforts to effectively repeal the Affordable Care Act (ACA) through the budget reconciliation process have garnered attention, Congress's recent passage of a bipartisan bill making targeted changes to the law...more

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