News & Analysis as of

The Affordable Care Act—Countdown to Compliance for Employers, Week 6: Labor and Treasury Departments Play Whack-a-Mole with...

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

IRS Guidance on the Application of the Affordable Care Act’s Market Reform Provisions to HRAs and FSAs

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

The IRS Says (Again) That Certain Employer Payment Plans Won’t Fly

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

Novel IRS Guidance on HRAs, VEBAs and Domestic Partner Benefits

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

IRS Notice 2013-54 Guidance Clarifying Impact of Affordable Care Act on HRAs, Health FSAs, and Employer Payment Plans

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

Flexible Spending Accounts Become More Flexible

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

The ERISA Litigation Newsletter; November 2013

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

More About HRAs And Some About EAPs

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

No More Pre-Tax Premiums For Individual Insurance Policies?

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

The Affordable Care Act Creates Compliance Challenges For HRAs And Other Arrangements

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

Monthly Benefits Update - September 2013

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

Agencies Release Guidance on HRAs, FSAs, and Employer Payment Plans

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

Labor and Treasury/IRS Opine on Integrated and Non-Integrated HRAs, Medical FSAs, and EAPs

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

Guidance on Applying PPACA Market Reforms to HRAs, Health FSAs, and Other Health Care Arrangements

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

DOL, IRS, and HHS Put the Brakes on Stand-Alone HRAs Used to Access Health Insurance Coverage in the Individual Market

In a set of Frequently Asked Questions (FAQs) posted to the Department of Labor’s website on January 24, the Departments of Health and Human Services, Labor, and Treasury (the “Departments”) put a stop to an approach to...more

Certain Plan Designs Will Cost More Under The Patient-Centered Outcomes Research Institute Fees

The Affordable Care Act establishes a Patient-Centered Outcomes Research Institute as a private nonprofit corporation to assist patients, clinicians, purchasers and policy makers in making informed health decisions using...more

Navigating Health Care Reform: Health Care Reform’s New Research Fees: What Employers Need to Know

Now that the Supreme Court has upheld the constitutionality of the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act (collectively, the “Act”), employers must move...more

Self-Insured and Insured Medical Plans, Including Stand-Alone Retiree Plans and HRAs, Are Subject to $1 Fee per Covered...

The IRS recently issued a proposed regulation explaining a new fee imposed by the Patient Protection and Affordable Care Act (PPACA). For calendar year plans, the fee begins this calendar year and remains in effect through...more

Proposed Rules Released Implementing New Fees on Health Plans

The Affordable Care Act mandates that a fee be assessed on health insurance issuers and plan sponsors of self-insured health plans to fund the Patient-Centered Outcomes Research Institute. The IRS recently proposed rules...more

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