News & Analysis as of

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

IRS Seeks to Curb Popularity of ‘Skinny’ Health Plans

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

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

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

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

Monthly Benefits Update

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

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

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

"Shared Responsibility" Final Regulations and 2015 Transition Guidance

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

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

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

Finally! IRS Provides Final Play-Or-Pay Guidance

On February 11, 2014, the IRS released final regulations implementing the employer shared responsibility provisions of the Affordable Care Act, also known as the “employer mandate” and “play-or-pay” requirement. In this...more

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

IRS Grants Partial, Temporary Relief from the Affordable Care Act’s Employer Mandate

Under the Affordable Care Act’s Employer Mandate, employers with 50 or more full-time equivalent employees are required to offer affordable, minimum value health coverage to at least 95% of their full-time employees (and...more

Monthly Benefits Update - February 2014

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

"ObamaCare" Delayed Again

On February 10, 2014 the IRS issued final regulations on the employer shared responsibility provisions under Section 4980H of the Internal Revenue Code. Here is a "Q&A" statement provided by the IRS that answers various...more

Final ACA Shared Responsibility Regulations Released

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

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

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

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

Another delay in the Affordable Care Act’s Employer Mandate - A Reprieve For Many Employers

The Obama administration announced last week that some mid-sized businesses would have an additional year to comply with the employer mandate or “pay or play” provisions of the Affordable Care Act. The employer mandate...more

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

Medium-Sized Employers Given a Temporary Break in PPACA Pay or Play Penalties

On February 12, 2014, the IRS published Final Regulations pertaining to the shared responsibility provisions of the Patient Protection and Affordable Care Act of 2010 (“PPACA”). Large employers are defined in PPACA as those...more

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

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

“Pay-or-Play” & Contingent Workers: Final Regulations Provide Clarity But Not Complete Relief

As previously reported, on February 10, 2014, the IRS issued final regulations on the Affordable Care Act’s (ACA) employer shared responsibility requirements—the so-called “pay-or-play” mandate. In the regulations, the IRS...more

IRS Issues Final Affordable Care Act “Pay Or Play” Regulations

On Monday, the IRS issued final regulations regarding the implementation of the employer shared responsibility provisions under the Affordable Care Act (the ACA), otherwise known as the “pay or play” rules. The final...more

Final Regulations on Play or Pay Mandate Provide Relief to Certain Employers

This week, the IRS issued final regulations concerning the Affordable Care Act’s “play or pay” (also known as the employer shared responsibility) mandate. This advisory describes highlights of these voluminous regulations,...more

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