News & Analysis as of

Recent Government-Issued FAQs Clarify ACA Employer Mandate, Market Reforms

Notice 2015-87 (the Notice) provides recent government guidance on the Affordable Care Act (ACA) employer mandate and market reforms. The Notice contains 26 frequently asked questions (FAQs) from the Internal Revenue Service...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

EEOC Loses Another Wellness Case, Part 2 – Beware the ACA Penalties

In my last blog post, I discussed a recent loss by the EEOC in its efforts to limit the ability of employers to require employees to complete health risk assessments (HRAs) or biometric screenings in order to enroll in the...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

Employee Benefits & Executive Compensation Advisory: IRS Notice 2015-87 Provides Much-Needed Guidance for Account-Based Plans and...

In IRS Notice 2015-87, the agencies provided further clarification on the impact of the Affordable Care Act (ACA) group health plan market reform provisions on account-based plans and much needed guidance on the Section 4980H...more

Integrated Health Reimbursement Accounts, Coordination with Family Coverage, and Notice 2015-87—Something’s Missing

Issued at the end of last year, Notice 2015-87 provided detailed guidance on a host of topics. The notice has been referred to colloquially in some quarters as the “pot luck” notice. Among other things, the notice, in Q&A 4,...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

HRA Access for Spouses and Dependents: A New Wrinkle for Form 1095-C

Imagine that you are filling out Internal Revenue Service Form 1095-Cs for 2015 for an employer that offers employees the opportunity to elect self-only or family coverage under a minimum value group health plan. The plan...more

Issue 98: Year-End Agency FAQs Address Many Unanswered ACA Concerns

This is the ninety-eighth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

IRS Issues New Guidance on ACA and Other Health Plan-Related Legal Requirements

In Notice 2015-87 the Internal Revenue Service (IRS) issued guidance on various health plan-related topics, including: (1) treatment of employer-provided opt-out payments for purposes of affordability under the Affordable...more

Alert: Affordable Care Act (ACA) End of Year Checklist

With the Affordable Care Act (“ACA”) nearly fully implemented and agency enforcement now underway, employers must be clear which provisions of the ACA apply to them. Any employer that sponsors a health plan for employees is...more

The ERISA Litigation Newsletter - December 2015

Editor's Overview - In this month's newsletter, we focus on the recent wave of guidance and case law related to the Affordable Care Act. We also discuss IRS Notice 2015-86, which provides guidance on the application of...more

Affordable Care Act Update – Some Questions Answered, Some Relief Granted

Within the last week, there has been a flurry of activity from both Congress and the Internal Revenue Service (“IRS”) with respect to the Affordable Care Act (“ACA”). This client alert first reviews the delayed effective date...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 22 of 24): Affordability, HRA Contributions,...

The Treasury Department and the IRS this week issued Notice 2015-87 that addresses, among other things, the effect of Health Reimbursement Account (HRA) contributions, cafeteria plan flex credits and opt-out payments on...more

Coming Down Your Chimney: Market Reform Guidance, Information Reporting Penalty Relief and Cadillac Tax Delay

It’s the “silly season” on the Hill and a busy season for ACA regulators. This article gives you brief notes about Notice 2015-87, information reporting relief and the § 4980I delay buried in the omnibus spending bill....more

IRS Notice 2015-87 (Part 1) – IRS Issues New HRA Integration Rules

On December 16, 2015, the Internal Revenue Service issued Notice 2015-87 containing guidance on a wide-range of topics under the Affordable Care Act (ACA). In addition to providing guidance on affordability and COBRA matters...more

Five Years Later, Final Rules on Grandfathered Plan Status, Etc.

Today, the ACA enforcement agencies (DOL, HHS, IRS) jointly published final rules, effective January 1, 2017, on grandfathered plan status, pre-existing condition exclusions, lifetime and annual limits, rescissions, dependent...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

End of Year Issues Impacting Employer Health Plans

With the end of 2015 fast approaching, employers should be aware of certain issues under the Patient Protection and Affordable Care Act (“ACA”), the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and...more

Reporting for ACA Mandates: Final Forms and Additional Guidance

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...more

IRS Releases Final Forms for Health Care Reform Reporting

With required reporting under the Affordable Care Act (ACA) looming, employers should be aware of the latest guidance from the IRS. As a reminder, information reporting requirements apply to all employers who are members of...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

Final 2015 Forms 1094-B, 1095-B, 1094-C, 1095-C and Instructions

On September 16, 2015, the IRS finalized these ACA coverage reporting Forms and Instructions... We report here, with minimal analysis, changes that we recognized on first comparison to the 2015 Draft Forms and Instructions....more

Employee Benefits Alert - August 2015

Retirement Plans - IRS Issues Guidance on Benefit Suspension Voting under MPRA - As we have written in prior alerts, the Multiemployer Pension Reform Act of 2014 (MPRA) permits trustees of financially troubled...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 5 of 24): Reporting of Health Reimbursement...

As we reported last week, the IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C. These instructions are of interest to applicable large employers who must report their compliance with the Affordable Care...more

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