Although many of the provisions of the Patient Protection and Affordable Care Act (PPACA) were already in effect, the pace of change has quickened since the Supreme Court upheld the law in June of 2012. The law is composed of...more
The U.S. Department of Health and Human Services has issued final regulations and a set of frequently asked questions and answers establishing standards for the provision of essential health benefits in the individual and...more
President Obama’s re-election confirmed that the Affordable Care Act will continue to be rolled out, and that its “pay-or-play” rules will become effective on January 1, 2014. These provisions require public and private...more
As a reminder of the significant role that states will play in implementing the provisions of the Affordable Care Act (ACA), we wanted to highlight some recent legislative developments in California that will be of interest...more
Beginning in 2014, large employers are subject to one of two “shared responsibility” penalties under the Patient Protection and Affordable Care Act (“ACA”), commonly known as the play or pay penalties. The Internal Revenue...more
The Affordable Care Act added the so-called “Play or Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2014, certain employers may be subject to a penalty tax,...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
In This Issue: - Health & Welfare Plans ..Health Care Reform: IRS Issues Proposed “Pay or Play” Regulations ..Health Care Reform: IRS Issues FAQs on Various ACA Issues ..HHS Issues Final HIPAA Regulations...more
In early January, the Internal Revenue Service published proposed regulations on “Shared Responsibility for Employers Regarding Health Coverage.” These regulations incorporate the provisions of many previous Notices with...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 January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more
The U.S. Treasury Department recently released new guidance to assist employers (generally those with 50 or more full-time or full-time equivalent employees) in preparing and planning for the 2014 requirement to offer...more
Under the Affordable Care Act, a large employer is subject to penalties if it fails to offer to full-time employees health coverage or if the coverage that it offers is not affordable or does not provide minimum value. These...more
Beginning in 2014, large U.S. employers that do not offer a minimum level of affordable health coverage to their full-time employees may be required to pay an assessment of up to $3,000 per employee. For plan years beginning...more
Beginning in 2014, the Patient Protection and Affordable Care Act (Act) requires “applicable large employers” (i.e., employers with 50 or more full-time equivalent employees) to either offer group health insurance coverage to...more
In this issue: - Assess the Workforce - Choose Whether to "Pay" or to "Play" - Evaluate Existing Wellness Programs and/or Implement New Wellness Programs to Enhance Employees' Health Profiles and to Avoid or Minimize...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
Full implementation of healthcare reform under the Affordable Care Act (ACA) is less than a year away. The most important aspect of the new system for employers is the "employer shared responsibility" or "play or pay"...more
Proposed regulations issued by the Internal Revenue Service on December 28, 2012 provide some relief to large employers subject to the employer-sponsored coverage mandate under health care reform. The employer mandate is...more
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