Your Guide to Understanding the Terms, Meeting the Requirements and Avoiding the Penalties - NOTE: The following article is the first of a three-part series, “Employer Responsibility for Health Coverage: Are You Ready...more
In This Issue: - Minimum Essential Coverage ..HHS Proposed Rule - Shared Responsibility Payments and Exemptions ..HHS Proposed Rule ..IRS Proposed Rule ..IRS Final Rule - Essential Health Benefits ...more
Although many of the provisions of the Patient Protection and Affordable Care Act (PPACA) were already in effect, the pace of change has quickened since the Supreme Court upheld the law in June of 2012. The law is composed of...more
As we have written in this space in the past, whether a worker is an employee or an independent contractor can have many consequences. The classification can determine whether the principal is liable for the negligent acts...more
The U.S. Department of Health and Human Services has issued final regulations and a set of frequently asked questions and answers establishing standards for the provision of essential health benefits in the individual and...more
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
As a reminder of the significant role that states will play in implementing the provisions of the Affordable Care Act (ACA), we wanted to highlight some recent legislative developments in California that will be of interest...more
Beginning in 2014, "large employers" may be assessed a penalty for not providing required coverage under the employer shared responsibility mandate of the Affordable Care Act. This does not mean that employers need not worry...more
Under the Affordable Care Act (“ACA”), a large employer is subject to penalties if it fails to offer to full-time employees and their dependents health coverage or if the coverage that it offers is not affordable or does not...more
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
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 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
Only applicable large employers may be assessed a penalty under the employer shared responsibility mandate of the Affordable Care Act. An applicable large employer is defined by the regulations as one that has employed an...more
In This Issue: - Top News ..CMS Announces Round 2 Competitive Bidding Single Payment Amounts ..CBO Lowers SGR Repeal Cost by $100 Billion ..Republicans Press HRSA on 340B Audits ..HHS Proposes...more
The IRS and the U.S. Department of Health and Human Services (HHS) have issued two important pieces of guidance under the Patient Protection and Affordable Care Act regarding the responsibilities imposed on individuals to...more
To make certain that 2013 will be as exciting as 2012, on January 2 the US Treasury issued proposed regulations under section 4980H of the Internal Revenue Code (“Code”), which was added to the Code by the Patient Protection...more
Several agency actions on the Affordable Care Act out of HHS and Treasury last week include proposed regulations detailing exemptions from the shared responsibility tax, such as an exemption for those who would qualify for...more
In This Issue: - Health & Welfare Plans ..Health Care Reform: IRS Issues Proposed “Pay or Play” Regulations ..Health Care Reform: IRS Issues FAQs on Various ACA Issues ..HHS Issues Final HIPAA Regulations...more
In early January, the Internal Revenue Service published proposed regulations on “Shared Responsibility for Employers Regarding Health Coverage.” These regulations incorporate the provisions of many previous Notices with...more
Earlier this month, the IRS issued proposed regulations that provide much-needed guidance on the new “pay or play” rules (also called the shared responsibility rules) that will apply to employers’ group health plans beginning...more
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
The U.S. Treasury Department recently released new guidance to assist employers (generally those with 50 or more full-time or full-time equivalent employees) in preparing and planning for the 2014 requirement to offer...more
Under the Affordable Care Act, a large employer is subject to penalties if it fails to offer to full-time employees health coverage or if the coverage that it offers is not affordable or does not provide minimum value. These...more
Beginning in 2014, large U.S. employers that do not offer a minimum level of affordable health coverage to their full-time employees may be required to pay an assessment of up to $3,000 per employee. For plan years beginning...more
Beginning in 2014, the Patient Protection and Affordable Care Act (Act) requires “applicable large employers” (i.e., employers with 50 or more full-time equivalent employees) to either offer group health insurance coverage to...more
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