News & Analysis as of

Monthly Benefits Update - July 2014

Two federal appeals courts issued contradictory rulings on the validity of subsidies for the purchase of health insurance under the federal marketplace established pursuant to the Affordable Care Act (ACA). On July 22, a...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 37: Stalking the Elusive “Variable Hour Employee”

For “applicable large employers” (i.e., generally, those employers who employed an average of at least 50 full-time employees on business days during the preceding calendar year), determining which employees are “full-time”...more

Employee Benefits: Is Your Health Plan Premium Affordable Under The ACA?

By now, most large employers are aware that they are required to offer "affordable" health care coverage to their full-time employees beginning in 2015 in order to avoid potential penalties under the shared responsibility...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

U.S. Privacy and Data Protection: 2013 Year in Review and a Look Ahead to 2014

In Boston, we celebrated Data Privacy Day (January 28) by presenting “U.S. Privacy and Data Protection: 2013 Year In Review and a Prediction of What’s to Come in 2014” for participants in an IAPP KnowledgeNet. Our panel of...more

Monthly Benefits Update - November 2013

Health & Welfare Plans - Health Care Reform: Supreme Court Grants Review to Two Cases Challenging ACA’s Contraception Coverage Mandate - The United States Supreme Court has agreed to hear two cases challenging...more

The Clock is Ticking -- October 1 Deadline Approaches for Employers to Issue Health Care Exchange Notice

U.S. Department of Labor (DOL) guidance issued under the Affordable Care Act (ACA) requires employers to provide employees with a notice regarding health care exchanges (now called "marketplaces"). ...more

IRS Issues Proposed Rules For Employer “Shared Responsibility”

With the Patient Protection and Affordable Care Act on the horizon, employers are focused on the costs associated with benefits plans and medical coverage....more

ACA Employer Play or Pay Requirements: What Does it Mean for Employers?

Beginning in 2014, the Affordable Care Act (ACA) will require “large” employers to offer their full-time employees healthcare coverage that meets certain standards or pay a penalty. Whether an employer opts to “play-or-pay”...more

The Benefits Game - Playbook for Compliance with the Health Care Reform’s Pay or Play Rules for Employers

The Affordable Care Act’s (ACA’s) employer shared responsibility provisions (commonly called “pay or play”) impact “large” employers and go into effect in 2014. Although effective in 2014, employers must plan NOW. Advance...more

IRS, Treasury Department Issue Proposed Rules Governing Minimum Value, Affordability, and Wellness Programs

A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more

Strategic Implementation of Employer Shared Responsibility Rules & 2014 Planning Considerations

In This Presentation: •Welcome •Overview of the Employer Shared Responsibility Rules - Impact on Corporate Structure - Time Line Examples to Demonstrate Application of Measurement, Administrative & Stability...more

Health Care Reform Implementation Update - April 26, 2013

Marilyn Tavenner received bipartisan support from members of the Senate Committee on Finance in her confirmation hearing to lead the Centers for Medicare and Medicaid Services (CMS) though a full Senate vote is being held up,...more

Countdown to 2014: Prepare for the Affordable Care Act Now

Originally published in New Hampshire Business Review on March 8, 2013. The Affordable Care Act is the most important piece of employee benefits legislation since the passage of ERISA in 1974. And in the past few...more

Affordable Care Act: Preparing for 2014

President Obama’s re-election confirmed that the Affordable Care Act will continue to be rolled out, and that its “pay-or-play” rules will become effective on January 1, 2014. These provisions require public and private...more

IRS Issues Proposed Regulations for Employer-Shared Responsibility under ACA

On December 28, 2012, the IRS issued proposed regulations with respect to employer-shared responsibility regarding health coverage under the Affordable Care Act of 2010 (ACA). Employers are permitted to rely on these proposed...more

Employers Subject To The Play Or Pay Penalties Under Health Care Reform

Beginning in 2014, large employers are subject to one of two “shared responsibility” penalties under the Patient Protection and Affordable Care Act (“ACA”), commonly known as the play or pay penalties. The Internal Revenue...more

The Affordable Care Act’s “Play Or Pay” Mandate: How It Works

The Affordable Care Act added the so-called “Play or Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2014, certain employers may be subject to a penalty tax,...more

IRS Releases Proposed Regulations on the Affordable Care Act's Play or Pay Mandate

On January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more

Employer Alert -- January 2013: IRS Proposed Regulations On PPACA’S Shared Responsibility Provisions Full of New Year Surprises...

On December 28, 2012, the Internal Revenue Service (“IRS”) issued long-awaited proposed regulations regarding the “shared responsibility” penalty provisions of the Patient Protection and Affordable Care Act (“PPACA”). In...more

IRS Issues Proposed Regulations on Employer Responsibility for Health Coverage

On December 28, 2012, the Internal Revenue Service (IRS) issued proposed regulations providing guidance with respect to employer shared responsibility regarding health coverage under the Affordable Care Act of 2010 (ACA). ...more

Health Care Reform: Preparations For 2014 Pay Or Play Rules Should Begin Now

By far the most important issue for employers to consider under the Affordable Care Act (ACA) is the employer “free rider penalty,” often referred to as “pay or play.” Instead of forcing employers to provide group health...more

For Employers, Pay-or-Play Proposals Could Be Worse, Much Worse

Could employee benefits regulatory activity under the Patient Protection and Affordable Care Act (Act) be taking a turn toward common sense?...more

IRS Releases Further Guidance on Employer Health Care Coverage Mandate and Penalties

The Internal Revenue Service has released proposed regulations and FAQs on the shared responsibility provisions of the Affordable Care Act (ACA). These rules require large employers to offer full-time employees and their...more

Proposed Regulations Issued on Employer Shared Responsibility Payments under the Affordable Care Act

Last Friday, the Department of the Treasury issued proposed regulations on the employer shared responsibility provisions in section 4980H of the Internal Revenue Code, under which an employer may be subject to an assessment...more

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