On December 15, 2022, the Internal Revenue Service (IRS) finalized regulations regarding Information Reporting of Health Insurance Coverage and Other Issues Under Internal Revenue Code (Code) Sections 5000A, 6055 and 6056...more
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
The IRS Office of Chief Counsel recently issued a memo which, in a surprise to many, concluded that the filing of the Affordable Care Act (“ACA”) Forms 1094-C and 1095-C (“C Forms”) does not start the statute of limitations...more
The IRS has not yet finalized the ACA reporting forms (i.e., the 1094-B/C and 1095-B/C) for the 2019 tax year, so it is no surprise that the IRS issued guidance this week extending the deadline to furnish the forms to...more
As reported in our “2018 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare,” the Tax Cuts and Jobs Act repealed the individual mandate, which spawned a lawsuit challenging the whole of the Affordable Care Act...more
Over the last few months, the Internal Revenue Service (IRS) has been replying to responses to their Letter 226-J, which notifies employers of a proposed Employer Shared Responsibility Payment (ESRP). The IRS has recently...more
If you believe your company was subject to the Affordable Care Act (ACA) coverage requirements in 2015 (generally, all employers with 50 full-time or full-time equivalent employees), please take note that the Internal Revenue...more
The deadline to respond is nearing for employers that received the first wave of Letter 226J mailings proposing to assess them with Employer Shared Responsibility Payments (ESRPs) for 2015 under Section 4980H of the Internal...more
In the next few months, the IRS will begin sending letters notifying employers that they may owe a penalty for failing to offer health coverage under the Affordable Care Act's Employer Mandate for the 2015 calendar year. The...more
Based on a recent audit conducted by the Treasury Inspector General for Tax Administration (TIGTA), the IRS’ processes and procedures to ensure compliance with the employer information reporting requirements mandated by the...more
In the wake of the President’s January 20, 2017 Executive Order directing a reduction in regulatory burdens imposed by the Affordable Care Act (ACA), the IRS has quietly announced that it will continue to process income tax...more
During his campaign, President-elect Trump promised to make the repeal and replacement of the Affordable Care Act (ACA) a priority. Now that the election is over, what should employers expect? We don’t have a crystal ball,...more
In Q&A format, recently issued Notice 2015-87 addresses a number of pressing issues that have arisen under the Affordable Care Act (ACA), including that law’s employer shared responsibility rules, information reporting...more
It took a while, but most employers and their advisors have finally gotten the hang of the Affordable Care Act’s employer shared responsibility rules. That is, they understand generally that: 1. “Applicable Large...more
The Affordable Care Act (ACA) has significantly changed the legal landscape for employer-sponsored health plans by adding reporting obligations, benefit mandates, fees, notices and potential penalties for plans that do not...more
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
By way of reminder, employers who employ at least 50 full-time employees (including full-time equivalents) on average during the calendar year of 2014 will be required to file Internal Revenue Service (IRS) forms 1095-C and...more
With the end of 2015 fast approaching, employers should be aware of certain issues under the Patient Protection and Affordable Care Act (“ACA”), the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and...more
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
When reporting offers of coverage to full-time employees under the Affordable Care Act’s (ACA) employer shared responsibility rules, much of the detail appears in Part II of IRS Form 1095-C, Lines 14, 15 and 16. For the most...more
The IRS recently released the final forms and instructions for information reporting under the Affordable Care Act (“ACA”). The final forms and instructions will be used for reporting in 2016 concerning 2015 coverage. The...more
More than five years after its enactment, the Affordable Care Act (ACA) continues to be one of the top concerns for employers, and rightly so: the ACA is one of the most comprehensive laws impacting employee benefits since...more
The Affordable Care Act’s reporting rules—which are set out in Internal Revenue Code §§ 6055 and 6056—solicit the information needed by the Internal Revenue Service to enforce the individual and employer shared responsibility...more
The Affordable Care Act’s (ACA) employer shared responsibility rules provide applicable large employers (i.e., those with 50 or more full-time and full-time equivalent employees on business days during the preceding calendar...more