News & Analysis as of

Internal Revenue Service Patient Protection and Affordable Care Act (PPACA) Pay or Play

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Saul Ewing LLP

Potential Year-End Surprise in Your Mailbox – A Letter from the IRS (updated)

Saul Ewing LLP on

The Affordable Care Act or ACA (a/k/a “Obamacare”) is not dead, yet. Employers are starting to receive letters from the IRS notifying them that they owe assessable payments (“penalties”) under the employer shared...more

Schwabe, Williamson & Wyatt PC

Beware: IRS To Begin Issuing ACA Employer Shared Responsibility Payment Penalty Notices

The IRS has announced its next steps regarding the Employer Shared Responsibility Payments (the “ESRPs”), which are the ACA penalties assessable to “Applicable Large Employers” for failing to provide affordable health care...more

Proskauer - Not for Profit/Exempt...

Recaps from Proskauer’s 21st Annual Trick of Treat Tax Exempt Seminar

Proskauer’s 21st Annual Trick or Treat Seminar was held on Thursday, October 27. The Seminar discussed: Best Practices for Document Retention: One Size Does Not Fit All...more

King & Spalding

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

King & Spalding on

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

Sherman & Howard L.L.C.

End of Year Issues Impacting Employer Health Plans

Sherman & Howard L.L.C. on

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

McNees Wallace & Nurick LLC

ACA Update: Supreme Court Rules that Federal Insurance Exchanges May Issue Tax Subsidies

On June 25, 2015, the U.S. Supreme Court issued its decision in King v. Burwell, ruling that Section 36B of the Patient Protection and Affordable Care Act (“ACA”) authorizes insurance exchanges run by the federal government...more

Littler

The Affordable Care Act and Staffing: One Size Does Not Fit All

Littler on

Since its enactment in 2010, the Affordable Care Act (ACA) has generated debate and questions about the law's impact on third-party staffing arrangements. With the effective date of the ACA's "pay-or-play" employer mandate...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 3: Group Health Plan, Cafeteria Plan and Health FSA...

As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more

McNees Wallace & Nurick LLC

Feds Tighten the Belt on "Skinny Plans" and Other ACA Workarounds

On January 1, 2015, employers with 100 or more "full-time equivalents" will be subject to the "Pay or Play" regulations under the Affordable Care Act ("ACA"). Over the past few years, many consultants have sought to identify...more

Ballard Spahr LLP

IRS Seeks to Curb Popularity of ‘Skinny’ Health Plans

Ballard Spahr LLP on

The Internal Revenue Service, in Notice 2014-69, has concluded that certain unconventional group health plan designs that offer limited or no coverage for in-patient hospitalization services and/or physician services will not...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 18: Emerging Strategies to Reduce or Eliminate Exposure for...

The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 20: 9.5% ≠ 9.56% (And Why It Matters to Applicable Large...

While employers sometimes view the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules in isolation, they don’t operate that way. Instead, they exist side-by-side with other provisions of the Act. In...more

Sherman & Howard L.L.C.

Affordable Care Act Update: Final Regulations Assist Employers With Identifying Full-Time Employees and Reporting Requirements

Earlier this year, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). We issued a Client...more

Franczek P.C.

Monthly Benefits Update

Franczek P.C. on

Health & Welfare Plans - July 1 Deadline to Begin Measuring Employee Hours for ACA Employer Mandate/“Pay or Play” - As we have discussed in many previous alerts, the Affordable Care Act’s employer shared...more

Foley & Lardner LLP

IRS' Final Employer Shared Responsibility Rules: Who is an "Applicable Large Employer"?

Foley & Lardner LLP on

Earlier this year, the IRS issued final regulations that provide additional guidance on the employer shared responsibility rules (also called the “pay or play” rules) that will generally apply to employers’ group health plans...more

King & Spalding

"Shared Responsibility" Final Regulations and 2015 Transition Guidance

King & Spalding on

In February, the Internal Revenue Service (the "IRS") issued final regulations under Section 4980H of the Internal Revenue Code (the "Code"), which establishes the employer "shared responsibility" (or "pay-or-play") mandate...more

Pillsbury Winthrop Shaw Pittman LLP

Health Care Reform Update: Employers Must Begin Reporting Details of Health Coverage to IRS

The Patient Protection and Affordable Care Act (“ACA”) imposes significant new reporting requirements on employers providing self-insured group health coverage to their employees and employers subject to the shared...more

Stinson - Benefits Notes Blog

ACA Pay Or Play: Is Your Dependent Coverage Compliant?

Now that the IRS has issued final regulations under Section 4980H, the so-called “pay or play” provision of the Affordable Care Act, employers are deciding how to determine whether employees are full-time (30 hours or more a...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 42: Treasury Department and IRS Issue Final Reporting Rules...

On March 5th, 2014, the Treasury Department and the IRS issued two final reporting rules of critical importance to employers...more

Franczek P.C.

Monthly Benefits Update - February 2014

Franczek P.C. on

Health & Welfare Plans - Health Care Reform: IRS Issues Final ACA “Pay or Play” Regulations - The IRS issued final regulations regarding the employer shared responsibility provisions under the Affordable Care...more

Morgan Lewis

Final ACA Shared Responsibility Regulations Released

Morgan Lewis on

Plan sponsors now have the final piece of the puzzle needed to finalize their 2015 pay-or-play strategies. The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently issued the highly...more

Proskauer - Employee Benefits & Executive...

Coverage of Dependents: Final “Pay-or-Play” Regulations Exclude Stepchildren and Others; Extend Prior Transitional Relief

As previously reported, the IRS recently released final regulations on the Affordable Care Act’s (ACA) employer “shared responsibility” provisions, also known as the “pay-or-play” mandate. Under the mandate, in order to avoid...more

Winstead PC

The First Pieces of Health Reform's Pay or Play Penalty Puzzle

Winstead PC on

Early this week the Internal Revenue Service and Department of Treasury (the “IRS”) issued the first piece of the Affordable Care Act (“ACA”) penalty imposition jigsaw puzzle. It then followed up with 46 FAQs on the same...more

Spilman Thomas & Battle, PLLC

Playing Kick the Can with the Affordable Care Act: The Administration Further Delays Employer Deadlines

The Treasury Department has announced further extensions for medium-sized and large-sized employers for compliance with the “employer mandate” of the Affordable Care Act (“ACA”). The employer mandate requires employers with a...more

Foley & Lardner LLP

Final “Pay or Play” Regulations Provide Transition Relief for Non-Calendar Year Plans

Foley & Lardner LLP on

Last week, the IRS issued final regulations that provide additional guidance on the new “pay or play” rules (also called the employer shared responsibility rules) that will generally apply to employers’ group health plans...more

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