News & Analysis as of

Safe Harbors Employer Mandates

Williams Mullen

IRS Reduces 2024 Affordability Percentage

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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

Happy Thanksgiving and the Many Things for Which We Are Thankful – 2022 Edition

This year brought substantial progress in the way of slightly fewer positive COVID-19 cases and/or transmissions and increased vaccinations. Consequently, in the employment world many of you reopened your offices and invited...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

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

Preparing for the New Massachusetts Equal Pay Law, Part I: Whether, When, and How to Conduct a Pay Equity Audit

The July 1, 2018, implementation date for the amendments to the Massachusetts Equal Pay Act (MEPA) is less than a year away. The amendments approved in 2016 will bring about substantial changes to the definition of...more

BCLP

Think Your PTO Policy Complies With the Chicago or Cook County Paid Sick Leave Ordinances? Think Again.

BCLP on

The City of Chicago’s (the “City’s”) and Cook County’s (the “County’s”) paid sick leave (“PSL”) Ordinances took effect on July 1, 2017, generally requiring employers to provide employees in Chicago and non-opt out locations...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

Fisher Phillips

Massachusetts Attorney General Publishes Final Earned Sick Time Regulations

Fisher Phillips on

On June 19, 2015, the Massachusetts Attorney General published the final regulations concerning the new Earned Sick Time (“EST”) law that will go into effect on July 1, 2015. These final regulations differ somewhat from the...more

Cooley LLP

Alert: Act Now: Massachusetts Mandatory Sick Leave Is Coming Soon

Cooley LLP on

As we previously reported, Massachusetts voters approved a ballot measure that will allow Massachusetts employees to earn and use sick time under certain conditions. Under the new Earned Sick Time law, employees who work for...more

Constangy, Brooks, Smith & Prophete, LLP

Some Employers To Get Six-Month “Safe Harbor” Under Massachusetts Sick Leave Law

As we have previously reported, on November 4, 2014, Massachusetts approved Ballot Question 4, titled “Earned Sick Time for Employees.” The new law will take effect July 1, but state Attorney General Maura Healey announced...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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