News & Analysis as of

The Affordable Care Act—Countdown to Compliance for Employers, Week 7: IRS Puts the Kibosh on Health Plans that Fail to Cover...

In a previous post, we described an Affordable Care Act compliance strategy—referred to commercially as a “minimum value plan” or “MVP”—that involves an offer of group health plan coverage that, while similar in most respects...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

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

Administration issues new game-changing health care reform regulations

On February 11th, the Treasury Department issued its much-anticipated final regulations on the Affordable Care Act’s (ACA) so-called employer mandate, under which certain employers have to either (a) offer affordable,...more

Treasury Issues Final Regulations Which Delay Employer Mandate - Applicable to Businesses With Less than 100 Employees

The Obama Administration initially delayed the imposition of the employer “shared responsibility” payment (applicable under Internal Revenue Code section 4980H) which required all employers with greater than 50 employees to...more

Small Employers Catch a Big Break!

Employers with 50 to 99 employees were granted a break on Monday when the U.S. Treasury Department gave them an additional year to comply with the employer mandate of the Affordable Care Act (ACA). This relief was granted as...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 45½: Treasury/IRS Issue Long-Awaited Final Regulations under...

Breaking with long standing tradition—i.e., issuing important rules on a Friday before a holiday weekend, or (failing that) any Friday (hence the reference to Week 45½ in this post)—the Treasury Department and the IRS today...more

Proposed Employer Tax Rules Available For Obamacare

The U.S. Department of the Treasury and the Internal Revenue Service have published proposed rules establishing reporting requirements for employers and insurers under the Affordable Care Act (“ACA”), or Obamacare....more

Obama Administration Postpones Health Care Reporting And Penalties Until 2015

On Tuesday, July 2, the Treasury Department announced that the Administration will delay the Affordable Care Act’s mandatory employer and insurer reporting requirements for another year. These requirements will not take...more

Employment Law Advisory for August 21, 2013: Health Care Reform: What Employers Need to Know Now

Last year, the United States Supreme Court upheld the Affordable Care Act, the sweeping health care law enacted by Congress and signed into law by President Obama in 2010. Many of the most important provisions of the law...more

Now for Everything Else: What Employers Still Need To Worry About Between Now And 2015

For the past several months (and, in many cases, years), most large employers have been preparing for the consequences of offering (or not offering) their workforce health coverage and complying with the complexities...more

Employer Responsibility – Will You Pay or Play? Part II - The Variable Hour or Seasonal Employee Problem

Although the employer mandate has been delayed to 2015, employers shouldn’t relax too much because significant planning still needs to be done now. Beginning in 2015 large employers either must offer full-time employees...more

IRS Guidance On Delay in Implementing Pay-or-Play Penalties of ACA Health Care Reform Law

The IRS issued Notice 2013-45 recently, the official guidance document explaining the one-year delay in the implementation of the employer pay-or-play penalties under the Patient Protection and Affordable Care Act ("PPACA")...more

Benefits Update, No. 3, August 2013: Healthcare Reform: What Was and Was Not Delayed?

On July 2, 2013, the U.S. Treasury Department delayed enforcement of the employer “play or pay” mandate penalties and reporting requirements one year to 2015, stating that covered employers should still comply with the...more

PCOR Trust Fund Fee Due Soon for Many Plans

Calendar-year plans should use updated IRS Form 720 and related instructions to file by July 31 deadline. Under the Affordable Care Act (ACA), for plan years ending on or after October 1, 2012, plan sponsors of...more

Health Care Reform Implementation Update - July 23, 2013

With only two weeks before Congress’ August recess and just a little more than two months before October open enrollment begins, Washington is busy sorting through, implementing and, in some cases, fighting the Affordable...more

U.S. Treasury Department Delays Enforcement of Employer Mandate and Reporting Requirements Under PPACA

As seen in many mainstream press reports, the Obama administration announced in early July that (1) the employer mandate and (2) certain reporting requirements under the Patient Protection and Affordable Care Act (PPACA) will...more

IRS/Treasury Provides One-Year Delay For Certain Employer Health Coverage Reporting And Employer “Pay Or Play” Penalty Taxes

On July 9, 2013, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued formal guidance (IRS Notice 2013-45; herein, the “Notice”)1 that provides for a one year delay until 2015 with respect to (i) certain...more

ACA Responsibility Payments, Mandatory Employer and Insurer Requirements Delayed

Those of you just arriving on the planet may have heard a little something about the Affordable Care Act and the fact that it has a lot of folks worried about just how it will all work....more

Healthcare Law -- Jul 15, 2013

How Does the DOMA Defeat Impact Healthcare Reform and Health Insurance Access? - NOTE: The Supreme Court's 5-4 decision to invalidate the Defense of Marriage Act (DOMA) will affect more than 1,000 federal statutes—and...more

Health Care Reform Employer Mandate Delayed; DOMA Struck Down - What Now For Employers?

Health Care Reform Employer Mandate and Reporting Provisions Delayed until 2015 - The U.S. Department of the Treasury unexpectedly announced on July 2, 2013 the delay of the employer shared responsibility ‘pay or play’...more

Department of Labor Sets October 1, 2013, Deadline For Employers To Give Employees Notice Of Exchange Available Under the...

On May 8, 2013, the Department of Labor (“DOL”) issued guidance to employers for giving notice to employees as required by Fair Labor Standards Act (“FLSA”) § 18b. Section 1512 of the Patient Protection and Affordable Care...more

The Affordable Care Act – Consider Yourself on Notice

Under the Affordable Care Act, employers subject to the Fair Labor Standards Act must provide a “Notice of Coverage Options” to each employee. The purpose of this Notice is to inform employees that they may obtain health...more

It’s Official: IRS Issues Guidance Affirming One-Year Delay in the Affordable Care Act Employer Mandate and Related Reporting...

On July 9, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....more

Legal Alert: Guidance Released On Delay Of "Pay Or Play" Penalties Under ACA

The Obama Administration has released formal guidance on the delay of the Affordable Care Act's (the "ACA") employer mandate and certain reporting requirements. ...more

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