News & Analysis as of

"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

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

IRS Final Rule Partially Delays ACA Employer Shared Responsibility Requirement

On January 10, 2014, the Internal Revenue Service (IRS) released final regulations governing the employer shared responsibility provisions of the Affordable Care Act (ACA). The final rule addresses application of the...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

They’re Back! Final Regulations On Employer “Pay-or-Play” Mandate Released – IRS Provides Transition Relief To Employers with...

On Tuesday, February 10, 2014, the IRS released final regulations on the Affordable Care Act’s (ACA) employer “shared responsibility” provisions, also known as the “pay-or-play” mandate. ...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

The Affordable Care Act—Countdown to Compliance for Employers, Week 51: Speculating about Code Section 4980H Transitional Relief

(Note: This is the first installment of a series of entries that Alden will be posting each week for the next 51 weeks as he counts down to the January 1st, 2015 ACA pay-or-play deadline). ...more

Proposed Health Coverage Reporting Rules Under the Affordable Care Act

In September, the Internal Revenue Service (the "IRS") issued proposed regulations under Sections 6055 and 6056 of the Internal Revenue Code (the "Code") that establish annual health coverage information reporting and...more

Affordable Care Act Checkup: 2014 Payroll

This past summer, the Obama administration decided to delay the “employer shared responsibility” portion (also known as the “employer mandate” or “pay or play mandate”) of the Affordable Care Act (the “ACA”) for one year...more

IRS Proposes Rules Regarding Information Reporting Requirements Under Sections 6055 and 6056 of the Affordable Care Act

Starting in 2014, the Affordable Care Act requires that nonexempt individuals either maintain “minimum essential coverage” or pay an individual payment with their income tax returns. Minimum essential coverage may be...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

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