News & Analysis as of

Health Insurance Internal Revenue Service

Bricker Graydon LLP

You May be Able to Increase Health Plan Premiums and Stay Affordable in 2025

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For the first time in four years, the IRS adjusted the affordability percentage used for the shared responsibility penalties. The IRS recently announced that the affordability percentage for 2025 will be 9.02%....more

Pillsbury Winthrop Shaw Pittman LLP

Developments in Association Law 2022 – 2024

The following is a review of notable cases and regulatory developments for nonprofit organizations at the federal and state levels during the last two years....more

Woodruff Sawyer

​​​​​IRS Issues Affordability Percentage Adjustment for 2025

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The Internal Revenue Service (IRS) has released Rev. Proc. 2024-35, which contains the inflation adjusted amounts for 2025 used to determine whether employer-sponsored coverage is “affordable” for purposes of the Affordable...more

Mandelbaum Barrett PC

2025 HSA and Excepted Benefits Inflation-Adjusted Limits

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The IRS released Rev Proc 2024-25, 2024-22 IRB 1333, dated May 9, 2024, which outlines the inflation-adjusted contribution limits for Health Savings Accounts (HSAs) for the year 2025, as determined under Code Section 223....more

Hall Benefits Law

Federal Agencies Issue Updated Instructions for Annual Submission of Gag Clause Prohibition Compliance Attestation

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​​​​​​​The U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the Internal Revenue Service (IRS) have updated the Submission Instructions and User Manual for the Gag Clause Prohibition...more

Pullman & Comley - Labor, Employment and...

Reminder: July 31 Is the PCORI Fee Remittance Deadline for Self-Insured Health Plans

Employers that sponsor a self-insured health plans must submit their Patient-Centered Outcomes Research Institute (PCORI) fees to the Internal Revenue Service by July 31, 2024. Plan sponsors need to calculate their PCORI fee...more

Dorsey & Whitney LLP

The Supreme Court Update - June 6, 2024

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The Supreme Court of the United States issued three decisions today: Becerra v. San Carlos Apache Tribe, No. 23-250: This case concerns the funding the Indian Health Service (“IHS”) must provide to Indian tribes that...more

Seyfarth Shaw LLP

IRS Releases Increased HSA Limits for 2025

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Seyfarth Synopsis: The IRS has announced increases to key limits for certain health and welfare benefit programs, including HSA contributions for 2025. The IRS recently released 2025 cost-of-living adjustments applicable to...more

Woodruff Sawyer

Navigating Mid-Year Benefit Election Changes

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One of the most common questions that we receive is whether an employee can change their benefits elections after the plan year has already started (also referred to as a mid-year change).  The answer is very fact-specific...more

McDermott Will & Emery

IRS Announces 2025 Limits for Health Savings Accounts, High-Deductible Health Plans and Excepted Benefit HRAs

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The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2024-25) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs) and...more

Laner Muchin, Ltd.

Employers Must Remain Vigilant in Addressing IRS Letters 226J for Employer Shared Responsibility Payments

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As we’ve previously discussed, the IRS started issuing Letters 226J in late 2017. It continues to send these letters to employers each year proposing that the employer owes an Employer Shared Responsibility Payment (ESRP) for...more

Bass, Berry & Sims PLC

Caution! Contents Hot: Key Benefits Issues to Watch During the Remainder of 2024

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While the sweltering roil of temporary regulatory changes related to the COVID-19 pandemic may have cooled and the initial burst of SECURE 2.0 steam begins to dissipate, sponsors of employee benefit plans should keep their...more

The Wagner Law Group

IRS Warns Companies are Making False Statements About Health Plan Reimbursements

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In IR-2024-65 (the “IR”), the IRS warns taxpayers that some companies are misrepresenting the circumstances under which food and wellness expenses can be paid or reimbursed under health flexible spending arrangements (“health...more

The Wagner Law Group

Merger and Acquisition Considerations for Employee Benefit Plans

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In the context of mergers and acquisitions, an acquisition target’s qualified retirement plans, health plans, executive compensation arrangements, and benefit programs (referred to collectively as “benefit programs”) can all...more

Maynard Nexsen

Advantages and Disadvantages of Offering a Level-Funded Group Health Plan

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While level-funded group health plans are not entirely new, their adoption has expanded rapidly over the last few years, particularly among small to midsized employers. According to an annual KFF survey, among employers with...more

Seyfarth Shaw LLP

IRS Releases 2024 Limits for Health and Welfare and Related Plans

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Seyfarth Synopsis: The IRS has announced an increase to the applicable dollar amount for determining the Patient-Centered Outcomes Research Institute (“PCORI”) Fee for 2024 as well as other health and welfare limits....more

Groom Law Group, Chartered

IRS Increases PCORI Fee

On October 18, the IRS issued Notice 2023-70, which increased the PCORI fee from $3 per covered life to $3.22 per covered life for policy and plan years that end on or after October 1, 2023 and before October 1, 2024....more

Woodruff Sawyer

Compliance Alert: IRS Releases PCORI Fee For Plan Years Ending Before October 1, 2024

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The IRS has released Notice 2023-70, which sets the applicable PCORI fee for plan years ending between October 1, 2023 and September 30, 2024 at $3.22 per covered life....more

Woodruff Sawyer

Affordability Under the ACA: How to Ensure Your Company Stays in Compliance

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n 2024, the Affordable Care Act (ACA) employer-coverage affordability percentage will be at the lowest threshold since the ACA came into effect. The IRS recently released the 2024 inflation-adjusted amounts, which decreases...more

Venable LLP

Important Change to ACA Electronic Reporting

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Beginning in 2024, almost all employers will need to file their Affordable Care Act (ACA) forms electronically. Previously, employers were required to file electronically only if they were filing 250 or more of a specific...more

Seyfarth Shaw LLP

Employers May Have to Pay More in 2024 as Affordability Threshold Hits New Low for Second Year in a Row

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Seyfarth Synopsis: The IRS has announced adjustments decreasing the affordability threshold for plan years beginning in 2024, which may cause employers to have to pay more for ACA compliant coverage in 2024. The IRS...more

Williams Mullen

IRS Reduces 2024 Affordability Percentage

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The Internal Revenue Service (IRS) decreased the Affordable Care Act (ACA) affordability percentage for 2024 to 8.39%. This percentage is used to assess whether an applicable large employer’s (ALE) lowest-premium health plan...more

Bass, Berry & Sims PLC

Planning for Open Enrollment? Note the ACA Affordability Threshold Drop

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On August 23, the Internal Revenue Service issued Rev. Proc. 2023-29, announcing that the Affordable Care Act (ACA) affordability threshold will be 8.39% for plan years beginning in 2024, a substantial decrease from the 9.12%...more

Snell & Wilmer

Tighter Margins: IRS Makes It More Difficult to Meet ACA Affordability Safe Harbors in 2024

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We have reported previously on the importance of understanding the coverage and reporting rules of the Affordable Care Act.  In particular, Code Section 4980H imposes penalties on large employers for failure to offer minimum...more

Baker Donelson

ACA Affordability Test Will Be More Difficult to Pass in 2024

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As employers are preparing for 2024 open enrollment, they should be aware that the Affordable Care Act (ACA) affordability safe harbors are going DOWN for 2024. The IRS has just released Revenue Procedure 2023-29, which...more

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