News & Analysis as of

Safe Harbors Patient Protection and Affordable Care Act (PPACA) Employer Mandates

Williams Mullen

IRS Reduces 2024 Affordability Percentage

Williams Mullen on

The Internal Revenue Service (IRS) decreased the Affordable Care Act (ACA) affordability percentage for 2024 to 8.39%. This percentage is used to assess whether an applicable large employer’s (ALE) lowest-premium health plan...more

Bradley Arant Boult Cummings LLP

7 Tips to Avoid Employer Mandate Assessments and Penalties under the Affordable Care Act

As we discussed in a prior article, it is now more important than ever for employers to ensure they fully and accurately complete IRS Forms 1094-C and 1095-C — forms required to be filed and/or furnished to employees under...more

Foley & Lardner LLP

Safe Harbors for Offering Health Coverage via an Individual Coverage Health Reimbursement Arrangement

Foley & Lardner LLP on

The Internal Revenue Service (“IRS”) released final regulations... that permit employers to set aside pre-tax funds into health reimbursement arrangements (“HRAs”) that can be used by employees to pay for premiums and other...more

Proskauer - Employee Benefits & Executive...

New HRA Regulations Part 5 – More on the Employer Shared Responsibility Mandate

On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 3 – Premium Tax Credit and Employer Mandate Impact on Individual Coverage HRAs

As part of our ongoing series on the final regulations expanding the availability of health reimbursement accounts (“HRAs”), we discussed the newly-created Individual Coverage HRAs, which generally allow for employers to...more

Foley & Lardner LLP

Under Developing IRS Guidance (Not Final), an Employer Would Be Able to Fully Satisfy ACA’s Employer Mandate Without Maintaining...

Foley & Lardner LLP on

Takeaway Message: A recent IRS notice provides a future path for employers to avoid ACA employer mandate penalties by reimbursing employees for a portion of the cost of individual insurance coverage through an...more

King & Spalding

New ACA Guidance Warrants Another "Checkup" of Employer Health Plans

King & Spalding on

On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....more

Mintz - Employment, Labor & Benefits...

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

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 6 of 24): Reporting Group Health Plan Opt-Out...

Under a common strategy for controlling group health care plan costs, employers sometimes adopt arrangements under which an employee is offered cash as an incentive to waive coverage. These arrangements are colloquially...more

Spilman Thomas & Battle, PLLC

Don't Forget! Preparing for the Affordable Care Act Employer Mandate

With 2015 just a few weeks away, employers with 100 or more full-time and full-time equivalent employees should be gearing up for the implementation of the Affordable Care Act (“ACA”) employer mandate, which subjects...more

Franczek P.C.

Monthly Benefits Update - July 2014

Franczek P.C. on

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

Bond Schoeneck & King PLLC

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

Pierce Atwood LLP

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

Pierce Atwood LLP on

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

Proskauer Rose LLP

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

Proskauer Rose LLP on

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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Helpful Guidance Issued on Employer Mandate Issues

Notice 2012-58 (August 31, 2012) describes a number of safe harbors related to the employer mandate under the Affordable Care Act. In today’s post, I want to focus on the Notice’s safe harbor method for determining the...more

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