News & Analysis as of

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

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

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

Group Health Plans: Year-End Action Items and Upcoming Changes - 2014

Employers should note upcoming cafeteria plan design changes that require an amendment no later than December 31, 2014 and other upcoming 2015 action items....more

The Affordable Care Act—Countdown to Compliance for Employers, Week 5: Health and Human Services (HHS) Wastes No Time Issuing...

Over the last couple of months, we have followed and reported on a particular ACA compliance strategy under which an employer subject to the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 6: Labor and Treasury Departments Play Whack-a-Mole with...

Last year, the Department of Labor and the Treasury Department/IRS (Departments) issued guidance on the application of certain of the Affordable Care Act’s insurance market reforms to health reimbursement arrangements (HRAs),...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 7: IRS Puts the Kibosh on Health Plans that Fail to Cover...

In a previous post, we described an Affordable Care Act compliance strategy—referred to commercially as a “minimum value plan” or “MVP”—that involves an offer of group health plan coverage that, while similar in most respects...more

Affordable Care Act Update: Hospitalization Services Required for Plan to Meet Minimum Value

On November 4, 2014, the Internal Revenue Service (IRS) released guidance (Notice 2014-69) clarifying that certain group health plans that do not provide for hospitalization services or physician services or both will fail to...more

Updated Timeline of Highlights for Employer Group Health Plan Compliance with the Affordable Care Act

Since enactment of the Affordable Care Act (“ACA”), the regulators have promulgated a myriad of regulations implementing the ACA’s requirements for group health plans. Over the past several years, the Obama administration has...more

IRS Issues New Forms And Instructions Regarding The Employer Mandate Information Reporting Requirements Under The ACA

In order to administer and enforce the rules of the Employer Shared Responsibility Mandate, the Affordable Care Act (ACA) added Sections 6055 and 6056 to the Internal Revenue Code, which require insurance providers and...more

California Repeals 60-Day Limit on Waiting Periods

On August 15, 2014, California passed Senate Bill 1034, which repealed an insurance law (Assembly Bill 1083) that prohibited insurance companies from including waiting periods in excess of 60 days in their group health...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 23: The Impact of Employment Contract Terms on Variable Hour...

For applicable large employers (i.e., employers who employed at least 50 full-time and full-time equivalent employees on business days during the preceding calendar year) endeavoring to comply with the Affordable Care Act’s...more

A Rocky Rollout for the Individual Mandate

It should be news to no one that the implementation of the Affordable Care Act (“ACA”) requirement that individuals without employer sponsored health insurance must be covered by minimum essential coverage (the individual...more

The Obamacare Delays and the Massachusetts "Fair Share" Employer Mandate: Now What?

As we reported in our post earlier today, the Obama administration has decided to delay implementation of the “employer shared responsibility” mandate for in order to afford employers more time to prepare for compliance. ...more

Employer Responsibility – Will You Pay or Play?

Starting in 2014, provisions of the Patient Protection and Affordable Care Act become effective known as “Pay or Play” or “Employer Shared Responsibility.” Large employers will be faced with the decision whether to offer...more

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