The IRS has announced its next steps regarding the Employer Shared Responsibility Payments (the “ESRPs”), which are the ACA penalties assessable to “Applicable Large Employers” for failing to provide affordable health care...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
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
As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more
Earlier this year, the IRS issued final regulations that provide additional guidance on the employer shared responsibility rules (also called the “pay or play” rules) that will generally apply to employers’ group health plans...more
Particularly with the issuance of final regulations under the Affordable Care Act’s employer shared responsibility rules, employers have been concerned—justifiably—with the pay-or-play penalties. ...more
In February, the Internal Revenue Service (the "IRS") issued final regulations under Section 4980H of the Internal Revenue Code (the "Code"), which establishes the employer "shared responsibility" (or "pay-or-play") mandate...more
Distinguishing employees who are full-time from those who are not takes up a good deal of real estate in final regulations published in the Federal Register on February 12 implementing the Act’s employer shared responsibility...more
On March 5th, 2014, the Treasury Department and the IRS issued two final reporting rules of critical importance to employers...more
Today, the U.S. Department of the Treasury and the Internal Revenue Service published Final Rules to implement the information reporting provisions for insurers and certain employers under the Affordable Care Act ("ACA"),...more
On February 10, 2014, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). The final regulations...more
In a move that will not come as a surprise to anyone who has been following the rocky implementation of the Affordable Care Act (“ACA”), the Obama Administration has yet again delayed important provisions of the ACA. In a...more
Health & Welfare Plans - Health Care Reform: IRS Issues Final ACA “Pay or Play” Regulations - The IRS issued final regulations regarding the employer shared responsibility provisions under the Affordable Care...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
So much attention has been paid to the issuance of the final employer shared responsibility regulations that some might have missed the news that final regulations were recently issued under another of the Affordable Care...more
Plan sponsors now have the final piece of the puzzle needed to finalize their 2015 pay-or-play strategies. The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently issued the highly...more
In This Issue: Implementation of the Affordable Care Act; Other Federal Regulatory Initiatives; Other Congressional and State Initiatives; and Hearings and Mark-Ups Scheduled. Excerpt from Implementation of the...more
In last week’s post on the topic of the recently issued final regulations under the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules, we suggested that the final regulations broke little new...more
Employers in all industries are well aware of the complexities of the Affordable Care Act, and the seemingly constant barrage of guidance that interprets the health care reform requirements that apply to them. We have a...more
As previously reported, the IRS recently released final regulations on the Affordable Care Act’s (ACA) employer “shared responsibility” provisions, also known as the “pay-or-play” mandate. Under the mandate, in order to avoid...more
Early this week the Internal Revenue Service and Department of Treasury (the “IRS”) issued the first piece of the Affordable Care Act (“ACA”) penalty imposition jigsaw puzzle. It then followed up with 46 FAQs on the same...more
The Treasury Department has announced further extensions for medium-sized and large-sized employers for compliance with the “employer mandate” of the Affordable Care Act (“ACA”). The employer mandate requires employers with a...more
Executive Summary: Under final regulations issued by the U.S. Treasury Department on February 10, 2014, employers with at least 50 but fewer than 100 employees will not be required to comply with the employer shared...more
On February 10, 2014, the Internal Revenue Service released final regulations pertaining to the Employer Shared Responsibility Mandate (commonly referred to as "Pay or Play") of the Patient Protection and Affordable Care Act...more
Earlier this week, the IRS issued final regulations that provide additional guidance on the new “pay or play” rules (also called the employer shared responsibility rules) that will generally apply to employers’ group health...more