Minimum Essential Coverage

News & Analysis as of

Staffing agency workers and ACA offers of coverage

The final regulations on the Affordable Care Act’s (ACA) “pay or play” rules were released on Feb. 10, 2014. Under the rules, there are potential penalties imposed on large employers that do not offer substantially all...more

ACA Reporting Deadline Extended — But Employers Should Stay Focused To Avoid Penalties

About a month ago, and just months before the reporting deadlines required under the Affordable Care Act (ACA) were set to go into effect, the Internal Revenue Service gave us all a late Christmas present and announced that...more

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

This post concludes our half-year series of posts focusing on the Affordable Care Act’s reporting requirements. These requirements are challenging in the extreme. Carriers and employers, and their vendors, service providers...more

IRS Extends Deadlines for 2015 ACA Reporting

Extension Provides Much-Needed Time to Accurately Complete First Year of Reporting - The IRS has extended the deadlines for information reporting by employers and coverage providers as required under the Affordable Care...more

IRS Extends 2015 Form 1095 Deadlines

Under the Affordable Care Act (ACA), applicable large employers (generally 50 or more full-time employees in previous year) must furnish each individual who was a full-time employee during 2015 with a Form 1095-C,...more

IRS Extends Deadlines for Affordable Care Act Reporting

On December 28, 2015, the IRS released Notice 2016-4, which extended the distribution and filing deadlines for the Affordable Care Act (ACA) reporting requirements set forth in Sections 6055 and 6056 of the Internal Revenue...more

Updated Tax Credit Eligiblity Clarification

Last week the IRS released the final regulation addressing the effect of various items on an individual’s eligibility for premium tax credits. Generally, premium tax credits are not normally available to individuals who are...more

Health Care Reform – What You Should Know For 2016

Unlike most other years since the Affordable Care Act (“ACA”) was passed, there are relatively few new requirements employers need to implement in connection with their health plans subject to the ACA. This Advisory...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 21 of 24): Reporting for “MEC” Plans

It took a while, but most employers and their advisors have finally gotten the hang of the Affordable Care Act’s employer shared responsibility rules. That is, they understand generally that: 1. “Applicable Large...more

Deadline Approaches to Execute a Cafeteria Plan Amendment for IRS Notice 2014-55

This is a re-issued advisory reminding health plan sponsors that if you have administered your cafeteria plan in accordance with this guidance, make sure to execute a formal plan amendment by the end of the 2015 plan year...more

HHS Appeals Adverse Decision on Fixed Indemnity Attestations

As expected, on Monday, November 9, 2015, the U.S. Department of Health & Human Services (HHS) filed a Notice of Appeal from the decision issued by Judge Royce Lamberth of the United States District Court for the District of...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

Navigating Legal Issues in Connection with Employer Sponsored On-Site Health Clinics

Employers are increasingly concerned with the high cost of health care and executives in the C-Suite are beginning to take notice. The Affordable Care Act (‘‘ACA’’) required employers who sponsor group health plans to adopt a...more

Final Forms and Instructions for ACA Information Reporting Released

The IRS recently released the final forms and instructions for information reporting under the Affordable Care Act (“ACA”). The final forms and instructions will be used for reporting in 2016 concerning 2015 coverage. The...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 12 of 24): Deconstructing Form 1095-C, Parts II...

This series is devoted principally to the reporting requirements imposed by Internal Revenue Code §§ 6055 and 6056 as added by §§ 1502 and 1514 of the Affordable Care Act (ACA), respectively. The former reports offers of...more

IREG Update - October 2015

Hot Topic - How Central United Life v. Burwell will affect the fixed indemnity market - Background - For many years, at least some state insurance regulators have sought to place limitations on the sale of fixed...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 11 of 24): Reporting 2015 Coverage of “MV-Lite”...

In Notice 2014-69, the Treasury Department and the IRS clarified that a group health plan that fails to provide substantial coverage for in-patient hospitalization and physician services will not be treated as providing...more

Manatt on Health Reform: Weekly Highlights - September 2015 #5

New study shows Marketplace premiums parallel the employer market; Montana likely to select a private insurer to administer benefits to its Medicaid expansion population; and Washington’s Exchange customers will begin paying...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

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 9 of 24): Unraveling the Mystery of Indicator...

The Affordable Care Act’s reporting rules—which are set out in Internal Revenue Code §§ 6055 and 6056—solicit the information needed by the Internal Revenue Service to enforce the individual and employer shared responsibility...more

Updated Proposed Regulations Issued: Inpatient Hospital and Physician Services Must Be Covered

Tuesday the IRS issued proposed regulations that require an employer-sponsored health plan to include substantial coverage of inpatient hospital and physician services in order for the plan be considered as providing minimum...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 6 of 24): Reporting Group Health Plan Opt-Out...

Under a common strategy for controlling group health care plan costs, employers sometimes adopt arrangements under which an employee is offered cash as an incentive to waive coverage. These arrangements are colloquially...more

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