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
On February 21, 2020, the Internal Revenue Service (IRS) released a memo to address whether the Employer Shared Responsibility Payment (ESRP) imposed by Internal Revenue Code (IRC) section 4980H is subject to any statute of...more
In Chief Counsel Memorandum 20200801F, released on February 21, 2020, the IRS established its position that no statute of limitations applies to employer shared responsibility payments that may be assessed under Section 4980H...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
The Internal Revenue Service has for some time made available a comprehensive set of Questions & Answers covering the Affordable Care Act’s (ACA) employer shared responsibility rules. (These are the rules that are codified in...more
As promised by the Centers for Medicare & Medicaid Services (CMS) in late-2015, the Federally-Facilitated Marketplaces (FFMs) have started sending notices informing employers that employees have enrolled in a FFM and were...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
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
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
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
Under the Affordable Care Act’s rules governing employer shared responsibility—which are codified in Internal Revenue Code § 4980H—where an applicable large employer makes an offer of group health plan coverage that is both...more
The federal health care reform law enacted in 2010, known as the Affordable Care Act, added a provision to the Internal Revenue Code (“Code”) (Code Section 4980H) that, beginning on January 1, 2015, may subject employers to...more
Enforcement of the employer shared responsibility provisions of the Affordable Care Act (ACA) has been further delayed for employers with between 50 and 99 full-time equivalent employees and temporarily eased for employers...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