News & Analysis as of

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

Roadmap to Compliance: Navigating the Employer Shared Responsibility Rules

Earlier this month, the IRS issued proposed regulations that provide much-needed guidance on the new “pay or play” rules (also called the shared responsibility rules) that will apply to employers’ group health plans beginning...more

Proposed Regulations Issued on Employer Shared Responsibility Payments under the Affordable Care Act

Last Friday, the Department of the Treasury issued proposed regulations on the employer shared responsibility provisions in section 4980H of the Internal Revenue Code, under which an employer may be subject to an assessment...more

Hurry Up and Wait—New Waiting Period Guidance for Health Plans

The government recently issued Notice 2012-59 (August 31, 2012), describing the 90-day limit for waiting periods to enter group health plans, as added by the Affordable Care Act (ACA). This notice provides temporary guidance...more

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