Shared Responsibility Rule Employer Group Health Plans

News & Analysis as of

You Received a Health Insurance Marketplace Notice from HHS – Now What?

Take a deep breath. The HHS Health Insurance Marketplace Notice (the “Notice”) may seem to be a nuisance, but it does not necessarily mean that you will be subject to employer shared responsibility penalties....more

When Anything Less than 95% is a Failing Grade: An Update on the Employer Shared Responsibility Penalties

As a reminder, effective January 1, 2016, employers must offer minimum essential coverage to 95% or more (up from 70% or more for 2015) of their full-time employees and their dependents each month or pay a very steep penalty....more

Code § 4980H: The Tax The Beatles Missed

The Tax Man, it turns out, also may assess you for failing to offer substantially all your full-time employees and their dependents affordable, qualifying group health coverage during 2015. We’re swamped with employer...more

Health Care and the ACA: IRS Formalizes Position on Opt-Out Payments

On December 16, 2015, the IRS, the Department of Health and Human Services, and Department of Labor issued Notice 2015-87, which provides guidance on the application of various provisions of the Affordable Care Act (ACA) to...more

Coming Down Your Chimney: Market Reform Guidance, Information Reporting Penalty Relief and Cadillac Tax Delay

It’s the “silly season” on the Hill and a busy season for ACA regulators. This article gives you brief notes about Notice 2015-87, information reporting relief and the § 4980I delay buried in the omnibus spending bill....more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 21 of 24): Reporting for “MEC” Plans

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’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

2015 End of Year Plan Sponsor “To Do” List Health & Welfare

As 2015 comes to an end, we are pleased to present you with our traditional End of Year Plan Sponsor “To Do” Lists. Like last year, we are presenting our “To Do” Lists in three separate Employee Benefits Updates. Part 1 of...more

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

Beware of Traps for the Unwary in Preparing ACA Information Returns (Part 1)

Beginning in 2015, certain applicable large employers may be assessed a payment as part of the “employer shared responsibility” provisions of the Affordable Care Act (ACA). Payment is assessable if the employer either (1)...more

Do Seasonal Workers “Count” for Forms 1094-C and 1095-C?

We were asked that recently, proving that there is such a thing as a wrong question. Let’s break it down. The same person may be both a “seasonal worker” and a “seasonal employee,” but those terms are used to discuss separate...more

The Affordable Care Act: What’s Ahead?

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 Requirements for Carriers and Employers (Part 9 of 24): Unraveling the Mystery of Indicator...

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 Reporting Requirements for Carriers and Employers (Part 8 of 24): Reporting Offers of Coverage “On...

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

Updated Proposed Regulations Issued: Inpatient Hospital and Physician Services Must Be Covered

Tuesday the IRS issued proposed regulations that require an employer-sponsored health plan to include substantial coverage of inpatient hospital and physician services in order for the plan be considered as providing minimum...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 7 of 24): Mergers and Acquisitions

When it comes to mergers and acquisitions involving at least one applicable large employer (ALE), the substantive rules governing employer shared responsibility (under Internal Revenue Code § 4980H) and the corresponding...more

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

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 5 of 24): Reporting of Health Reimbursement...

As we reported last week, the IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C. These instructions are of interest to applicable large employers who must report their compliance with the Affordable Care...more

Issue 92: IRS Releases Final Employer Reporting Forms and Instructions

As we previously reported in Issue 80, the Affordable Care Act (ACA) requires providers of minimum essential health coverage and applicable large employers to file annual reports with the IRS to report the coverage provided...more

The Big Picture of the Employer Shared Responsibility Tax

Ever since the Treasury Department in early 2014 issued final regulations on the employer shared responsibility tax (ESR tax)1 and the related final reporting regulations (ESR regulations)2 under the Patient Protection and...more

ACA Countdown to Compliance - 52 Week Series For Employers

In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more

Beware of Stop-Loss Coverage Gaps When Choosing a Self-Funded Major Medical Plan

The Affordable Care Act requires applicable large employers to make broad-based offers of group health insurance coverage to substantially all their full-time employees or face potential tax penalties. (The term “applicable...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 3: Group Health Plan, Cafeteria Plan and Health FSA...

As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more

The Affordable Care Act – What You Need to Know Checklist

In This Presentation: - Review Employer Information - Fees - Mandates - Additional Points - Communications - Excerpt from Review Employer Information. Employer’s Health Plans - 1. Identify the...more

The Waiting is the Hardest Part: Final Regulations on the PPACA’s 90-Day Waiting Period Released

On February 24, 2014, the Internal Revenue Service (IRS), the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL), and the U.S. Department of Health and Human Services (HHS) jointly released...more

43 Results
|
View per page
Page: of 2
JD Supra Readers' Choice 2016 Awards

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×