News & Analysis as of

Safe Harbors Patient Protection and Affordable Care Act (PPACA) Shared Responsibility Rule

Bricker Graydon LLP

You May be Able to Increase Health Plan Premiums and Stay Affordable in 2025

Bricker Graydon LLP on

For the first time in four years, the IRS adjusted the affordability percentage used for the shared responsibility penalties. The IRS recently announced that the affordability percentage for 2025 will be 9.02%....more

Fisher Phillips

5 Most Important Steps for Employers Doing Their 2023 ACA Compliance Planning

Fisher Phillips on

Applicable large employers must adhere to many Affordable Care Act (ACA) rules to remain compliant regarding group health plan offerings. We offer the following checklist of the five most helpful reminders you should take...more

Mintz - Employment Viewpoints

Treasury Department and IRS Proposed Individual Coverage HRA Affordability Safe Harbors

As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...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

Ballard Spahr LLP

Proposed Regulations Provide Additional Guidance on Individual Coverage HRAs

Ballard Spahr LLP on

The U.S. Department of the Treasury has issued proposed regulations addressing how individual coverage health reimbursement arrangements (ICHRAs) can comply with the Employer Shared Responsibility Payments (ESRP) requirements...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

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 20 of 24): Reporting Affordability on Form...

Affordability—i.e., whether health coverage is “affordable”—occupies an important place in the Affordable Care Act’s (ACA) regulatory scheme. Under that law’s individual mandate, no penalties are imposed for failure to...more

Mintz - Employment, Labor & Benefits...

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

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

Morgan Lewis

Final ACA Shared Responsibility Regulations Released

Morgan Lewis on

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

Baker Donelson

IRS Issues Proposed Regulations for Employer-Shared Responsibility under ACA

Baker Donelson on

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

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

Perkins Coie

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

Perkins Coie on

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

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

McNees Wallace & Nurick LLC

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

Manatt, Phelps & Phillips, LLP

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

Franczek P.C.

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

Franczek P.C. on

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

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

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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

King & Spalding

Identifying Full-Time Employees for Purposes of the Shared Responsibility Rules

King & Spalding on

Starting in 2014, the Patient Protection and Affordable Care Act (PPACA) will impose shared responsibility penalties on large employers that fail to offer health coverage to all of their full-time employees (or offer health...more

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