News & Analysis as of

Applicable Large Employers Should Determine Their Full-Time Employees For ACA Purposes And Prepare For Reporting In 2016

By way of reminder, employers who employ at least 50 full-time employees (including full-time equivalents) on average during the calendar year of 2014 will be required to file Internal Revenue Service (IRS) forms 1095-C and...more

Health Update - November 2015

Best Practices for Using Social Media in Healthcare: Maximizing Impact, Mitigating Risk - Editor's note: In a generation more likely to seek health information online than see a doctor, social media is playing an...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 18 of 24): Terminations, Changes in Status and...

The final regulations under Code § 4980H establish two—and only two—methods for determining an employee’s status as full-time: the monthly measurement method and the look-back measurement method. Under the former (as the name...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 17 of 24): Reporting for Offers of Coverage and...

The recently enacted Bipartisan Budget Act of 2015 repealed Section 1511 of the Affordable Care Act (ACA), which generally would have required employers with more than 200 full-time employees to automatically enroll new...more

New ACA Reporting: Frequently Asked Questions About Form 1095-C

For many employers, the employer mandate under the Affordable Care Act (ACA) is already a reality. Having now worked out some of the administrative kinks associated with providing the health plan coverage required by the...more

Issue 95: Health Care Reform Reporting Is Coming: Is Your Company Prepared?

This is the ninety-fifth issue in our series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of certain aspects...more

ACA Reporting 101

One of the new Affordable Care Act (ACA) requirements imposed on employers is the obligation to report employee group health plan coverage information to the IRS and employees on Forms 1094-C and 1095-C. The first required...more

Request for Information about ALE Reporting Status

We work closely with employers (mostly ALEs) and an array of service providers – payroll processors, benefit plan consultants and administrators, software developers and transmitters, employee leasing firms, insurance brokers...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

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

Preparing for the Approaching ACA Reporting Deadlines

With ACA reporting deadlines quickly approaching, many employers should be preparing to address the various reporting requirements in order to avoid the significant fines and penalties associated with non-compliance. As of...more

CMS Sends Long-Awaited Medicare 60-Day Overpayment Rule to OMB for Final Clearance

CMS is moving ahead on its much-anticipated final rule implementing Affordable Care Act (ACA) requirements on reporting and returning of Medicare overpayments. Under the ACA, enrolled providers and suppliers (and certain...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 14 of 24): Coding Form 1095-C, Part II for...

When reporting offers of coverage to full-time employees under the Affordable Care Act’s (ACA) employer shared responsibility rules, much of the detail appears in Part II of IRS Form 1095-C, Lines 14, 15 and 16. For the most...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 13 of 24): Coding Form 1095-C, Part II for...

Compliance with the Affordable Care Act’s (ACA) employer shared responsibility rules requires that applicable large employers identify their full-time employees. A “full-time employee” for this purpose is an employee who...more

Potential Penalties Creating Adjustments to Health Care Coverage Plan Offerings

What ACA-related issues have had the most impact on welfare benefit plans and may surface during 2016? JRN: 2015 is the year when the potential to be penalized for not offering employee health care coverage that is both...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

Reporting for ACA Mandates: Final Forms and Additional Guidance

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...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

Employee Benefits Developments - September 2015

IRS Issues New Draft Form 1095-C and Instructions. On August 6, 2015, the IRS published its most recent updates to Form 1095-C and the instructions for Forms 1094-C and 1095-C. Beginning in early 2016, applicable large...more

The Affordable Care Act: What’s Ahead?

More than five years after its enactment, the Affordable Care Act (ACA) continues to be one of the top concerns for employers, and rightly so: the ACA is one of the most comprehensive laws impacting employee benefits since...more

IRS Issues Final ACA Information Reporting Forms and Instructions

With three months remaining in 2015, the IRS has issued final forms and instructions that employers will need to use to satisfy the Affordable Care Act (ACA) information reporting requirements. The final forms and...more

Five Evolving Issues Confronting Employers in the Hospitality Industry

As the hospitality industry continues to grow and expand, one common goal is to provide all-inclusive experiences for visitors and patrons. Unfortunately, given the breadth of the goods and services offered to the public and...more

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