Health Insurance Internal Revenue Service

News & Analysis as of

Deadline Reminder for Employers and Providers: Electronically File Information Returns with IRS by June 30

Self-insured employers, applicable large employers and health coverage providers are reminded that the June 30 deadline to electronically file information returns with the IRS is approaching. The deadline to provide...more

The ERISA Litigation Newsletter - May 2016

Editor’s Overview - In this issue of Proskauer's ERISA Litigation Newsletter, we review a recent ruling by the Tenth Circuit Court of Appeals concerning the application of controlled group principles to the building...more

Employee Benefits Developments - May 2016

Agencies Issue New FAQs on the Affordable Care Act.The Departments of Labor, Health and Human Services, and the Treasury (the agencies) issued another set of frequently asked questions (FAQs) regarding the implementation of...more

Affordable Care Act: Understanding Employer Notices From the Marketplaces

The Affordable Care Act (ACA) established Health Insurance Marketplaces (also called Exchanges) where individuals can shop and enroll in health coverage. Individuals who meet certain criteria are eligible for premium...more

IRS Denial of Section 501(c)(3) Status for a Commercial ACO

The IRS recently released a ruling, Private Letter Ruling (“PLR”) 201615022, denying Section 501(c)(3) tax-exempt status to a “commercial” accountable care organization (“ACO”). This is the IRS’ first published guidance...more

DOL Issues Guidance Regarding Interaction Between Affordable Care Act And Fringe Benefit Requirements Under Service Contract,...

The Davis Bacon Act and the Davis Bacon Related Acts (collectively “DBRA”) and the Service Contract Act (“SCA”) impose additional obligations related to fringe benefits and wages on covered contractors. With the passing of...more

Cadillac Tax: A Levy in Limbo

The future of the Cadillac tax, a key cost-control mechanism and federal revenue source enacted as part of the Patient Protection and Affordable Care Act (ACA), is unclear. Though initially set to take effect in 2018,...more

New ACA, et. al. FAQs Cover Items From “Top” to “Bottom”

On April 20, the “Big Three” agencies (DOL, Treasury/IRS, and HHS) released another set of FAQs (the 31st, for those of you counting at home). Consistent with earlier FAQs, the new FAQs cover a broad range of items under the...more

A&B Healthcare Week in Review

I. REGULATIONS, NOTICES, & GUIDANCE - On April 15, 2016, the Food and Drug Administration (FDA) issued a proposed rule entitled, “Applications for Approval and Combinations of Active Ingredients Under Consideration for...more

ACA Reporting: IRS Deadline of March 31 Looms for Applicable Large Employers

Applicable large employers have new reporting requirements under the Affordable Care Act (ACA). Whether an employer is an applicable large employer is determined each calendar year by looking at the employer's workforce...more

Manatt on Health Reform: Weekly Highlights - March 2016 #2

The IRS releases guidance on resolving Form 1095 conflicts; New Hampshire's Medicaid expansion renewal clears a hurdle in the State; and New York providers get $1.5 billion in long-awaited DSRIP capital and infrastructure...more

New ACA Guidance Warrants Another "Checkup" of Employer Health Plans

On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....more

Employee Benefits Developments - February 2016

IRS Issues Guidance Regarding Application of ACA Fee to Expatriate Health Plans. Section 9010 of the Affordable Care Act (ACA) imposes an annual fee on covered entities engaged in the business of providing health insurance...more

Student Health Plans and ACA Compliance: New Relief for Educational Institutions

Educational institutions face unique issues when complying with the requirements of the Affordable Care Act (ACA). One such issue relates to the administration of student health insurance plans. On February 5, 2016, three...more

If You Blinked You Might Have Missed Important Affordable Care Act Guidance

Notice 2015-87 issued by the IRS on December 16, 2015, provides guidance on numerous Affordable Care Act provisions. Below are some of the highlights....more

Agencies Confirm that Certain Student Health Insurance Subsidies for Student Employees May Violate the Affordable Care Act

Colleges and universities often offer to subsidize the cost of health coverage for student employees, either through the purchase of an individual health insurance policy or through a “premium reduction arrangement” designed...more

Health Coverage Providers: Deadlines for Health Coverage Providers to Report Minimum Essential Coverage are Approaching

Who Must Report? If you are a health insurance issuer, self-insured employer, or other entity that providedminimum essential coverage (MEC) during calendar year 2015, including a state government providing Medicaid or...more

The Affordable Care Act’s Reporting Electronic Backbone—The AIR System

For the last half of 2015, we spent a good deal of time explaining the Affordable Care Act reporting requirements that applied to carriers and large employers. This post examines the how of ACA reporting. In particular, it...more

ACA Reporting Deadlines Relaxed for 2016

Following complaints, concerns and continuing questions relating to the Affordable Care Act reporting requirements, the IRS has relaxed reporting deadlines for 2016 in the form of IRS Notice 2016-4. As you may be aware,...more

FAQs Regarding the ACA’s Employer Reporting Requirements (Part 1 of 2)

The employer reporting requirements under The Patient Protection and Affordable Care Act (the "ACA") are generally effective beginning January 1, 2015, with the applicable reports filed in early 2016. The purpose of the...more

Employee Benefits Developments - January 2016

IRS Guidance Addresses Numerous ACA Issues Related to HRAs. Just before the New Year, the IRS issued Notice 2015-87 (Notice), addressing the application of Affordable Care Act (ACA) market reform rules to different...more

Manatt on Health Reform: Weekly Highlights - January 2016 #2

Minnesota's Task Force recommends maintaining their State-based Marketplace while Oregon considers bringing back theirs; CMS narrows the criteria for special enrollment periods; and President Obama seeks an extension of full...more

IRS Reduces Voluntary Compliance Program Filing Fees for Most Plans

The IRS recently published its annual update on user fees, Revenue Procedure 2016-8, which now includes fees for Voluntary Compliance Program (“VCP”) applications filed with the IRS pursuant to the Employee Plans Compliance...more

Extension of ACA 2015 Reporting Deadlines Provides Welcome Relief for Employers

The Affordable Care Act (“ACA”) imposes various reporting requirements on insurers, self-insuring employers, and other providers of “minimum essential coverage" and imposes penalties on coverage providers that do not comply....more

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