News & Analysis as of

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

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

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

Obama Administration Seeks Comments on Proposed Changes to Summary of Benefits and Coverage Document and Requirements

On December 30, 2014, the Departments of Health and Human Services, Labor, and the Treasury (collectively, “Departments”) issued a proposed rule (“Proposed Rule”) regarding the summary of benefits and coverage (“SBC”) for use...more

Legal Alert: Ring in the New Year with New Summary of Benefits and Coverage Requirements for 2015

On December 30, the Departments of Treasury, Labor, and Health and Human Services published a joint notice of proposed rulemaking modifying the Summary of Benefits and Coverage (SBC) final regulations issued in 2012. In...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

DOL and Treasury Update 2014-2015 Regulatory Agendas for Employee Benefits

The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. The updated plans are reflected in the attached chart. ...more

Employer Cash Payments To Reimburse Employees For Health Insurance Costs – No!

Many employers offer or provide cash to employees to reimburse them for the cost of purchasing an individual health insurance policy. Others offer employees with high claims risk a choice between enrolling in the company’s...more

DOL Gives States More Control Over Self-Insured Health Plans

On November 6, 2014, the U.S. Department of Labor, Employee Benefits Security Administration (DOL) published Technical Release 2014-01, which provides technical guidance to States concerning stop-loss insurance. Stop-loss...more

The Waiting is the Hardest Part: Final Regulations on the PPACA’s 90-Day Waiting Period Released

On February 24, 2014, the Internal Revenue Service (IRS), the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL), and the U.S. Department of Health and Human Services (HHS) jointly released...more

Save The Date: Oct. 1, 2013 — ACA Open Enrollment Begins

A fundamental feature of the Patient Protection and Affordable Care Act (“ACA” or “Act”) is the introduction of health care exchanges, or marketplaces, where individuals and small businesses may purchase “affordable” and...more

DOL, IRS, and HHS Put the Brakes on Stand-Alone HRAs Used to Access Health Insurance Coverage in the Individual Market

In a set of Frequently Asked Questions (FAQs) posted to the Department of Labor’s website on January 24, the Departments of Health and Human Services, Labor, and Treasury (the “Departments”) put a stop to an approach to...more

U.S. Department of Labor Postpones Affordable Care Act’s Employer Health Insurance Notice Requirement

On January 25, 2013, the United States Department of Labor (DOL) announced that it would postpone the implementation of a provision of the Affordable Care Act (ACA) that will require employers to inform employees about health...more

Employers Receive Additional Time to Provide Exchange Notice to Employees

As most are aware, 2013 is an important transition year when it comes to complying with the Affordable Care Act....more

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