Last year, the Department of Labor and the Treasury Department/IRS (Departments) issued guidance on the application of certain of the Affordable Care Act’s insurance market reforms to health reimbursement arrangements (HRAs),...more
Analysis: HRAs are employer-funded accounts designed to reimburse employees for out-of-pocket medical expenses. Employees are not permitted to contribute their own funds, so they are unlike flexible spending accounts or...more
What Is a Health Plan Identifier (HPID)?
A health plan identifier is a standardized 10-digit number that is unique to a plan.
Who Must Obtain an HPID in the Coming Weeks?
Large “controlling health plans”...more
The Internal Revenue Service (IRS) recently published guidance in Notice 2013-54 (the “Notice”) on the application of certain market reform provisions of the Affordable Care Act to Health Reimbursement Accounts (“HRAs”),...more
This Client Alert has the purpose of briefly analyzing the key provisions of the Hydrocarbons Act (the “Act” or the “HA”) and the Hydrocarbon Revenues Act (the “HRA” or, together with the HA, the “Hydrocarbon...more
The IRS recently issued two new Q&As to underscore that arrangements allowing employers to reimburse employees on a pre-tax basis for premiums used to purchase individual health coverage, either inside or outside of a public...more
Health Reimbursement Arrangements (HRAs) are used to help employees pay for medical expenses incurred by the employee, his or her spouse, dependents, and any children who, at the end of the taxable year, have not attained age...more
The Internal Revenue Service (IRS) recently provided guidance on several issues never before addressed. The guidance came in the form of a Private Letter Ruling (PLR), to be released later this year to the public under the...more
Notice 2013-54 (the "Notice") provides guidance clarifying the impact of certain market reform provisions of the Affordable Care Act ("ACA") on health reimbursement arrangements ("HRAs") and other group health plans under...more
Group health plan sponsors turn their attention to completing 2013 tasks, implementing upcoming 2014 changes, preparing for the ACA Shared Responsibility requirement in 2015, and documenting recent extensive plan changes....more
Flexible Spending Accounts (FSAs) or Health FSAs for years have let employers provide pre-tax dollars through employee salary reductions or employer contributions to an FSA account that the employee can spend as he or she...more
In This Issue:
- Labor and Employment and ERISA Class Actions After Wal-Mart and Comcast — Practice Points for Defendants (Part I – Commonality)*
- Agencies Release Guidance on HRAs, FSAs, and Employer Payment...more
On September 13, 2013, the Internal Revenue Service, U.S. Department of Labor and U.S. Department of Health and Human Services, collectively, issued guidance (the "Health Funding Guidance") on the application of two of the...more
Recently issued guidance clarifies the application of certain provisions under the Affordable Care Act (ACA) to health reimbursement arrangements, employer payment plans, health flexible spending arrangements and employee...more
Plan sponsors should review their health reimbursement arrangements, employer payment plans, health flexible spending arrangements, and employee assistance programs to ensure they comply with ACA market reforms....more
I blogged recently about IRS and Department of Labor (DOL) guidance restricting the ability of employers to subsidize individual health insurance premiums for their employees after December 31, 2013. That IRS and DOL guidance...more
Over the years we have seen some employers, particularly small employers, choose to provide health coverage to their employees by paying all or part of the premium for individual insurance policies that the employees have...more
On September 13, 2013 the U.S. Department of the Treasury (IRS), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of Labor (DOL), collectively referred to herein as the Departments, coordinated...more
Health & Welfare Plans -
Health Care Reform: FAQ Part XVI Addresses Insurance Exchange Notice and 90-Day Waiting Period Requirement.
The Treasury, the Department of Labor and the Department of Health and Human...more
On Friday, September 13, 2013, the IRS released Notice 2013-54 and the DOL issued Technical Release 2013-03 in substantially identical form. This guidance, which is generally effective January 1, 2014, provides much needed...more
On September 13, 2013, the Department of Labor and the Treasury Department/IRS (the “Departments”) issued coordinated guidance on a handful of items relating to the implementation of the Affordable Care Act (the “Act”),...more
On September 13, the U.S. Department of Labor (DOL) and the Internal Revenue Service (IRS) issued new guidance1 relating to the applicability of the Patient Protection and Affordable Care Act (PPACA) to certain kinds of...more
The first payment of the Patient-Centered Outcomes Research Institute (PCORI) fee imposed by the Affordable Care Act is due next week on July 31st. While the U.S. Treasury Department has delayed implementing certain health...more
Calendar-year plans should use updated IRS Form 720 and related instructions to file by July 31 deadline.
Under the Affordable Care Act (ACA), for plan years ending on or after October 1, 2012, plan sponsors of...more
The U.S. Department of Health and Human Services (HHS) Essential Health Benefits Final Rule and actuarial value regulations offer few surprises and much needed certainty to enable group health plans and health insurance...more
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