News & Analysis as of

2015 End of Year Plan Sponsor “To Do” List Health & Welfare

As 2015 comes to an end, we are pleased to present you with our traditional End of Year Plan Sponsor “To Do” Lists. Like last year, we are presenting our “To Do” Lists in three separate Employee Benefits Updates. Part 1 of...more

IRS Adjusted ACA Fee Amounts for the 2015/2016 Policy or Plan Years and Additional Payment Options

The Patient-Centered Outcomes Research Institute (PCORI) fee was established under the Affordable Care Act (ACA) to advance comparative clinical effectiveness research. The PCORI fee is assessed on issuers of health insurance...more

PCORI Fee Inflation Adjustment

In Notice 2015-60 (October 9, 2015), the IRS announced that the PCORI fee will rise to $2.17 per covered life for plan years ending on or after October 1, 2015 and before October 1, 2016. For plan years ending on or after...more

More Cadillac Plan Tax Guidance from IRS

Code § 4980I (a/k/a/ the “Cadillac Plan tax”) was added by the ACA so that taxpayers with average group health plans would not subsidize, by tax preference, rich plans benefitting chiefly the rich. Section 4980I imposes a...more

Employee Benefits Alert - July 2015

Major Revisions to Qualified Plan Determination Letter Process Announced - Effective January 1, 2017, the staggered five-year determination letter remedial amendment cycles for individually designed plans will be...more

IRS Notice 2015-43 Addresses Expatriate Health Coverage

New guidance from the Internal Revenue Service (IRS) leaves in place the limited Affordable Care Act (ACA) exemptions set out in the Expatriate Health Coverage Clarification Act of 2014 (EHCCA). IRS Notice 2015-43 (Notice)...more

Upcoming Health and Welfare Plan Requirements Checklist for Employers

As the mid-way point of 2014 approaches, employers should actively turn their attention to several upcoming compliance obligations for the health and welfare benefit plans they sponsor. Below is a checklist of upcoming...more

Departments Release Guidance on Dental and Vision Plans, EAPs, and "Wraparound" Coverage

On December 20, 2013, the Departments of Treasury, Labor, and Health and Human Services (collectively, the Departments) jointly issued proposed rules (Proposed Regulations) that would amend the regulations regarding excepted...more

Reminder: PCORI Fee Due July 31 for Employers With Self-Insured Health Plans

As previously reported, the Patient Protection and Affordable Care Act (the “ACA”) established the Patient Centered Outcomes Research Institute (the “PCORI”) for the purpose of assisting patients, clinicians, purchasers and...more

Certain Employers That Sponsor Group Health Plans Must Report And Pay The Patient-Centered Outcome Research Institute Fee By July...

As previously mentioned in the June 11, 2013 edition of The Fast Laner, the Patient Protection and Affordable Care Act created the Patient-Centered Outcomes Research Institute (PCORI) that is to be partially funded through...more

PCORI Fee Payment and Filing Deadline is July 31, 2013

The Affordable Care Act has established a new annual fee, imposed on group health plans, which will be used to fund the Patient Centered Outcomes Research Institute. The amount of the fee is $1 times the average number of...more

The Employer’s Playbook for Affordable Care Act Compliance: Self-Insured Plans - Remember - July 31, 2013 Deadline for Paying...

Media coverage of the one year delay in certain Affordable Care Act provisions might mislead some employers into thinking they have no obligations. Many requirements still take effect this year and in 2014. Here is one of 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

Important Reminder Regarding PCORI Fees

An important deadline is looming under the Affordable Care Act (ACA) for employers that sponsor certain self-insured group health plans and issuers of certain health insurance policies. Under the ACA, employers and insurers...more

ACA’s “Pay-Or-Play” Penalty Delayed Until 2015

Last week, in a move welcomed by many employers, the Obama administration announced that it would delay implementation of certain key provisions of the Affordable Care Act (ACA) until 2015....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

Employers Face Compliance Options In Lights Of Delayed Implementation Of Pay Or Pay Mandate Under The ACA, But Other ACA...

On July 2, 2013, the Treasury Department’s announced that enforcement of the "Pay or Play" mandate under the ACA will be delayed until January 1, 2015. This announcement was followed by a brief notice from the IRS which...more

The ERISA Litigation Newsletter - July 2013

As Amy Covert and Aaron Feuer discuss below, the U.S. Supreme Court granted certiorari in Heimeshoff v. Hartford Life & Accident Insurance Co. where it is expected to rule next term on whether plan sponsors may dictate in the...more

IRS Guidance Released on the Delayed Implementation of the Affordable Care Act's Play or Pay Rules - Penalties Will Not Apply to...

On the heels of last week’s announcement that the Affordable Care Act’s (ACA) reporting requirements and Play or Pay penalties will not go into effect until 2015, the IRS has released transition relief clarifying that the...more

ACA "Pay Or Play" Deadline Extension — What It REALLY Means

On July 2, 2013, the U.S. Treasury announced that the Obama Administration is implementing a one-year delay of the employer and insurer reporting requirements under the Affordable Care Act of 2010 ("ACA"). ...more

What the Obamacare Delay Means Right Now

On July 2, 2013, the Department of the Treasury and the White House announced via social media that the employer reporting requirements and employer shared responsibility/play-or-pay penalty are being delayed until 2015. ...more

Play or Pay Rules—Compliance Delayed Until 2015

On July 2, 2013, the Obama administration announced through the U.S. Department of the Treasury that the penalties for employers under the “Play or Pay Rules” will not go into effect until 2015....more

Affordable Care Act Shared Responsibility Penalty Delayed Until 2015

Employers welcome a one-year delay in the Shared Responsibility excise tax. On July 2, the U.S. Department of the Treasury (Treasury) made a surprise announcement—in an unusual place—that implementation of the employer...more

PPACA Update: Employer Shared Responsibility Mandate Delayed Until 2015

Many employers received a welcome, though temporary, reprieve Tuesday, when the U.S. Department of the Treasury (“Department”) announced a one-year delay in the effective date of one of the key requirements of the Patient...more

Treasury Announces Large Employer Play or Pay Penalties Will Be Delayed For One Year

On July 2, 2013, the Treasury Department informally announced that large employers will have an additional year to comply with the employer shared responsibility penalty provisions in Section 4980H of the Internal Revenue...more

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