You may have woken up today to media reports of large employers exploring the idea of dropping traditional health plans in favor of very limited health care plans as a way to lessen the burden imposed on large employers for...more
A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more
The U.S. Department of the Treasury has published proposed regulations that provide guidance on how an employer may determine whether its group health plan provides “minimum value.”...more
Starting in 2014, provisions of the Patient Protection and Affordable Care Act become effective known as “Pay or Play” or “Employer Shared Responsibility.” Large employers will be faced with the decision whether to offer...more
The Departments of Labor, Treasury, and Health & Human Services have issued new guidance on the content requirements for health plan summaries of benefits and coverage (“SBCs”). Plan sponsors should ensure that the SBCs...more
Earlier this week the Agencies issued a revised Summary of Benefits & Coverage (“SBC”) template for use in describing health plan coverage that begins on or after January 1, 2014 and before January 1, 2015. ...more
Recently, we published a Client Update explaining how the Play-or-Pay mandate, or Employer Shared Responsibility provision, under the Affordable Care Act (ACA) generally works. To summarize, we described how an employer...more
In This Issue: The ACA’s Effects on the Employer Insurance Market; Using the Premium Assistance Option to Purchase Coverage for Medicaid Beneficiaries in the Exchange: A Review of the Legal, Policy and Operational Issues; and...more
Beginning in 2014, the Affordable Care Act’s employer shared responsibility rules, the so called “play or pay” rules, impose penalties on an employer with more than 50 “full-time equivalent” employees (a large employer) if...more
The core policy goals of the Patient Protection and Affordable Care Act (the “Act”)—on which there is near universal consensus—are threefold: expand health care coverage; increase the quality of medical outcomes, and reduce...more
Proposed rules issued under the Affordable Care Act clarify the determination of “large employer” status and the calculation of the penalty for controlled groups of employers. This guidance confirms that the penalty is...more
In This Issue: What Does the ACA Mean for Employers?; Manatt’s Attorneys Honored for Exceptional Client Service; and Manatt Health Solutions Expands Our Talent Base to Support Your Growing Range of Challenges....more
It is impossible to ignore. Healthcare reform under the Affordable Care Act is on the minds, agendas and budgets of all employers, and now is the time for employers to review their health programs to address compliance with...more
In This Issue: - Minimum Essential Coverage ..HHS Proposed Rule - Shared Responsibility Payments and Exemptions ..HHS Proposed Rule ..IRS Proposed Rule ..IRS Final Rule - Essential Health Benefits ...more
As a reminder of the significant role that states will play in implementing the provisions of the Affordable Care Act (ACA), we wanted to highlight some recent legislative developments in California that will be of interest...more
On December 28, 2012, the IRS issued proposed regulations with respect to employer-shared responsibility regarding health coverage under the Affordable Care Act of 2010 (ACA). Employers are permitted to rely on these proposed...more
The Affordable Care Act added the so-called “Play or Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2014, certain employers may be subject to a penalty tax,...more
CMS and the Internal Revenue Service (IRS) issued two proposed rules on January 30, 2013 setting forth the exemptions an individual may satisfy to avoid financial penalties associated with the Patient Protection and...more
Starting in 2014, "large" employers (essentially, those with 50 or more "full-time" employees) must offer minimum health insurance coverage to full-time employees or face hefty penalties. These provisions (a.k.a "shared...more
Beginning in 2014, the Affordable Care Act will require employers employing 50 or more full-time equivalent employees to offer full-time employees affordable, minimum essential health coverage. If such health coverage is not...more
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