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
Employers have begun to receive notices from the Health Insurance Marketplace Exchanges (Marketplace) notifying them that one or more of their employees is eligible for governmental subsidies under the Marketplace. Employers...more
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
Reports in the popular media portrayed King v. Burwell as a case involving premium tax subsidies used to purchase health insurance from public exchanges or marketplaces under the Affordable Care Act (ACA). According to an...more
In our previous blog post, we evaluated the legal issues at stake in King v. Burwell. We will now examine some of the ramifications of a Supreme Court decision that goes against the Obama Administration, assuming such were to...more
Wrapping up the 2015 enrollment period, Healthcare.gov and State-based Marketplaces in seven states have announced special enrollment periods (SEPs) for people who were uninsured in 2014 and discover they owe a “shared...more
A recent Federal Court decision turned back a potentially debilitating challenge to the Affordable Care Act’s rules governing premium subsidies. The decision, Halbig v. Sebelius, has consequences for large employers, i.e.,...more
Under the Affordable Care Act (ACA), an employer subject to the Fair Labor Standards Act must provide a written notice to current employees about the Health Insurance Marketplace (the “Exchange Notice”) by October 1, 2013,...more
Looming implementation of the Affordable Care Act's (ACA) so-called “play or pay” provision has large employers evaluating the alternatives it presents: “play,” by offering health insurance coverage to full-time employees; or...more
Final regulations required for October 1, 2013 open enrollment are largely unchanged from the proposed rule. On August 30, the Centers for Medicare & Medicaid Services (CMS) of the Department of Health and Human...more
Video transcript: Hi, I’m Jess Rogers. I’m an attorney with Sands Anderson. As you probably know by now, on July 2nd the Obama administration announced a one year delay in the Affordable Care Act’s employer...more
Under the Affordable Care Act (ACA), individuals and small businesses will be able to purchase health insurance coverage online through the new health insurance coverage exchanges (now known as “Marketplaces”)....more
Established as a part of the comprehensive 2006 Massachusetts health care reform law, the Massachusetts Health Insurance Connector (a/k/a the “Connector”) served as a model for the American Health Benefit Exchanges that are a...more
With only two weeks before Congress’ August recess and just a little more than two months before October open enrollment begins, Washington is busy sorting through, implementing and, in some cases, fighting the Affordable...more
January 1, 2014 is fast approaching and regulators, payor organizations, providers, and many other interested parties are working to implement, operationalize, and participate in the state-based American Health Benefit...more
How Does the DOMA Defeat Impact Healthcare Reform and Health Insurance Access? - NOTE: The Supreme Court's 5-4 decision to invalidate the Defense of Marriage Act (DOMA) will affect more than 1,000 federal statutes—and...more
Under the Affordable Care Act, employers subject to the Fair Labor Standards Act must provide a “Notice of Coverage Options” to each employee. The purpose of this Notice is to inform employees that they may obtain health...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
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
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