Late last year, the Internal Revenue Service (the “Service”) began enforcing penalties with respect to failures to comply with the employer shared responsibility provisions of Section 4980H of the Internal Revenue Code. In...more
As 2017 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are presenting our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 will cover...more
You may recall that President Trump signed an executive order on the day of his inauguration directing all agencies to minimize the economic burden of the Affordable Care Act (ACA) pending its repeal. You may recall also that...more
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
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
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
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
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 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
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
Could employee benefits regulatory activity under the Patient Protection and Affordable Care Act (Act) be taking a turn toward common sense?...more
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