Health Insurance Employer Group Health Plans Safe Harbors

News & Analysis as of

November and December 2015 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...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

The ERISA Litigation Newsletter - September 2015

Editor's Overview - It has been a little more than one year since the U.S. Supreme Court altered the legal landscape for litigating ERISA breach of fiduciary duty claims relating to the investment in employer stock...more

The (Poorly Named) “Cadillac Tax” Part Two: IRS Provides Further Guidance in Notice 2015-52

The so-called “Cadillac Tax” (Internal Revenue Code Section 4980I) applies starting in 2018 and was intended to provide a means to address what were perceived as overly rich employer-provided health benefit plan designs, as...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 6 of 24): Reporting Group Health Plan Opt-Out...

Under a common strategy for controlling group health care plan costs, employers sometimes adopt arrangements under which an employee is offered cash as an incentive to waive coverage. These arrangements are colloquially...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

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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