Health Insurance Employer Group Health Plans Internal Revenue Service

News & Analysis as of

The “Cadillac Tax” is Rollin’ In!

When healthcare reform was rolled out in 2010, there was a provision included in the law imposing a tax on healthcare benefits provided to employees that exceed a threshold cost. This tax has been referred to as the...more

Increased Penalties for Information Returns

On June 29, 2015 the penalties under Code section 6721 and 6722 for failures relating to the filing of information returns required by numerous sections of the Code, including the ACA's new reporting for health coverage...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 2 of 24): Yikes! The Costs of Failing to Comply...

The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...more

Health and Welfare Benefits for Same-Sex Spouses after Obergefell: A New Mandate for Employers?

After last month’s decision by the U.S. Supreme Court in Obergefell v. Hodges, employee benefit plan sponsors may wonder whether Obergefell affirmatively imposes an obligation for employers to provide health, life,...more

Government Finalizes Religious Accommodation, But What About Health Plans, TPAs and PBMs?

In a set of rules published last week, the government finalized a July 2010 interim final rule (“IFR”) related to coverage of certain preventive services and an August 2014 IFR regarding the definition of an eligible...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 1 of 24)

Alden Bianchi, Chair of the our Employee Benefits & Executive Compensation Practice, will provide a weekly installment on the complex reporting obligations outlined by the Affordable Care Act for health insurance carriers and...more

Agencies Issue Final Regulations on the Summary of Benefits and Coverage (SBC) Requirements

As promised in the FAQ issued on March 30, 2015, the U.S. Departments of the Treasury, Labor and Health and Human Services (the Departments) have issued final regulations regarding the summary of benefits and coverage (SBC)...more

Supreme Court Denies Significant Challenge to Affordable Care Act: Employers Should Continue to Follow the Act as Currently...

On June 25, 2015, the U.S. Supreme Court held in King v. Burwell that individual taxpayers who enroll in health plans through the federal government's health insurance exchange can be eligible for federal tax credits under...more

IRS Notice 2015-43 Addresses Expatriate Health Coverage

New guidance from the Internal Revenue Service (IRS) leaves in place the limited Affordable Care Act (ACA) exemptions set out in the Expatriate Health Coverage Clarification Act of 2014 (EHCCA). IRS Notice 2015-43 (Notice)...more

How to Comply With the Affordable Care Act's Employer Mandate

The Affordable Care Act (“ACA”) is the most far-reaching piece of employee benefits legislation passed in the last 40 years. With over 20,000 pages of regulations and other guidance, the ACA is profoundly affecting our...more

Supreme Court Upholds ACA Subsidies on Federal Exchanges: McGuireWoods Healthcare Reform Guide: Installment No. 51

This is the 51st 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

Agencies issue proposed regulation on summary of benefits and coverage and uniform glossary

In December of 2014, the Employee Benefits Security Administration of the Department of Labor (“DOL”), the Internal Revenue Service (“IRS”) and the Department of Health and Human Services (“HHS”) (collectively, the...more

Administration Releases Final ACA Summary of Benefits and Coverage and Uniform Glossary Rule

On June 12, 2015, the Internal Revenue Service, Employee Benefits Security Administration, and Centers for Medicare & Medicaid Services released final regulations regarding the summary of benefits and coverage (SBC) and the...more

Employer Paid Individual Health Insurance Policies Create the Potential for Significant Penalties, But Limited Relief Is Available

Despite guidance from the Internal Revenue Service (“IRS”), the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) indicating the prohibition of the practice under the Affordable Care Act...more

The ACA’s Toyota tax

For several years now, employers have spent a great deal of time focusing on the Affordable Care Act’s (ACA) play-or-pay mandate. Numerous articles have been written and numerous educational seminars have been given...more

Some Good News For Small Employers with Employer Premium Payment Plans

Since the Affordable Care Act (the “ACA”) was enacted, many employers offered “employer payment plans” to effectively cover employee health insurance plans. Per IRS Notice 2013-54, however, employer payment plans are group...more

IRS Traded in Your Chevy for a “Cadillac (ac-ac-ac-ac-ac) Tax”: Agency Issues First Guidance on the Implementation Code Section...

On February 23, 2015, the Internal Revenue Service (IRS) issued the first piece of guidance that discusses the excise tax, better known as the “Cadillac Tax,” imposed by Section 4980I of the Internal Revenue Code of 1986, as...more

Limited Relief for Certain Employer Health Plan Premium Payments or Reimbursements

Under so-called “employer payment plans” (“EPPs”), an employer pays or reimburses an employee for substantiated premium costs under individual health plan insurance coverage (i.e., nonemployer individual health plan...more

IRS Clarifies That After-Tax HRAs and Other Individual Health Insurance Payment Arrangements Generally Violate the Affordable Care...

Any employer who offers an arrangement that reimburses employees (or pays directly) for premiums or other medical costs of individual health insurance coverage, including a health reimbursement account ("HRA") provided in...more

BEST IN LAW: Employers need to heed Obamacare Reporting Rules

Compliance with reporting obligations is always important for any employer, but the employer reporting requirements under the Affordable Care Act pack a significant penalty that makes compliance particularly...more

IRS Provides Temporary Enforcement Relief for Small Employers Offering Employer Payment Plans

The IRS issued guidance providing enforcement relief through June 30, 2015 for small employers who offer employer payment plans to their employees. In the guidance, the IRS reiterated its stance that an employer payment...more

IRS Releases Preliminary Guidance on “Cadillac Plan” Tax under ACA

The IRS released Notice 2015-16, which represents the first piece of guidance issued by a regulatory agency on the excise tax on high cost employer-sponsored health coverage, colloquially known as the “Cadillac plan” tax. The...more

2014 – June, 30 2015 Relief from Employer Excise Tax for Small Employer & S Corporation Payment or Reimbursement of Individual...

Beginning in 2014, a violation of certain healthcare reform rules, such as offering a health plan with annual dollar limits or not providing full preventive care with no employee cost, requires employers to pay an excise tax...more

Final IRS Forms and Instructions for Reporting Health Coverage Clarify Large Employer Requirements for 2015 and Beyond

On February 8, 2015, the IRS released final forms and instructions for reporting health coverage pursuant to Code Sections 6055 and 6056, which were added by the Health Care Reform Act. As stated below, large employers and...more

Monthly Benefits Alert - February 2015

Health & Wellness Plans - Anthem Data Breach Requires Plan Sponsor Attention - On January 29, 2015, Anthem Inc., one of the largest managed health care companies in the country, disclosed that the sensitive...more

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