As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more
On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23 – 27, 2019. September 24, 2019: The IRS issued a notice that provides a safe...more
On February 5, 2016, the Departments of the Treasury, Labor, and Health and Human Services (the Departments) issued guidance addressing the application of market reforms and other provisions of the Affordable Care Act (ACA)...more
Guidance from HHS and Treasury sets a high bar for 1332 waiver approvals; Kentuckians support Medicaid expansion and their State Marketplace despite plans to change course; and South Dakota's executive budget includes funds...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 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
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
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
July 2, 2013, the U.S. Treasury Department posted a blog announcing its intention to delay – until January 1, 2015 -- the imposition of penalties under the Affordable Care Act for large employers that do not offer health...more
On July 2, 2013 the U.S. Treasury Department announced that enforcement of the Affordable Care Act’s (“ACA”) employer penalties will be delayed until 2015....more