News & Analysis as of

U.S. Treasury Pay or Play

McDermott Will & Emery

A New Day for the HRA

McDermott Will & Emery on

The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 7: IRS Puts the Kibosh on Health Plans that Fail to Cover...

In a previous post, we described an Affordable Care Act compliance strategy—referred to commercially as a “minimum value plan” or “MVP”—that involves an offer of group health plan coverage that, while similar in most respects...more

Morgan Lewis

Final ACA Shared Responsibility Regulations Released

Morgan Lewis on

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

Spilman Thomas & Battle, PLLC

Playing Kick the Can with the Affordable Care Act: The Administration Further Delays Employer Deadlines

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

McAfee & Taft

Administration issues new game-changing health care reform regulations

McAfee & Taft on

On February 11th, the Treasury Department issued its much-anticipated final regulations on the Affordable Care Act’s (ACA) so-called employer mandate, under which certain employers have to either (a) offer affordable,...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Small Employers Catch a Big Break!

Employers with 50 to 99 employees were granted a break on Monday when the U.S. Treasury Department gave them an additional year to comply with the employer mandate of the Affordable Care Act (ACA). This relief was granted as...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 45½: Treasury/IRS Issue Long-Awaited Final Regulations under...

Breaking with long standing tradition—i.e., issuing important rules on a Friday before a holiday weekend, or (failing that) any Friday (hence the reference to Week 45½ in this post)—the Treasury Department and the IRS today...more

Hinshaw & Culbertson LLP

Proposed Employer Tax Rules Available For Obamacare

The U.S. Department of the Treasury and the Internal Revenue Service have published proposed rules establishing reporting requirements for employers and insurers under the Affordable Care Act (“ACA”), or Obamacare....more

BakerHostetler

Now for Everything Else: What Employers Still Need To Worry About Between Now And 2015

BakerHostetler on

For the past several months (and, in many cases, years), most large employers have been preparing for the consequences of offering (or not offering) their workforce health coverage and complying with the complexities...more

Poyner Spruill LLP

Employer Responsibility – Will You Pay or Play? Part II - The Variable Hour or Seasonal Employee Problem

Poyner Spruill LLP on

Although the employer mandate has been delayed to 2015, employers shouldn’t relax too much because significant planning still needs to be done now. Beginning in 2015 large employers either must offer full-time employees...more

Stoel Rives LLP

IRS Guidance On Delay in Implementing Pay-or-Play Penalties of ACA Health Care Reform Law

Stoel Rives LLP on

The IRS issued Notice 2013-45 recently, the official guidance document explaining the one-year delay in the implementation of the employer pay-or-play penalties under the Patient Protection and Affordable Care Act ("PPACA")...more

Fisher Phillips

Benefits Update, No. 3, August 2013: Healthcare Reform: What Was and Was Not Delayed?

Fisher Phillips on

On July 2, 2013, the U.S. Treasury Department delayed enforcement of the employer “play or pay” mandate penalties and reporting requirements one year to 2015, stating that covered employers should still comply with the...more

Morgan Lewis

PCOR Trust Fund Fee Due Soon for Many Plans

Morgan Lewis on

Calendar-year plans should use updated IRS Form 720 and related instructions to file by July 31 deadline. Under the Affordable Care Act (ACA), for plan years ending on or after October 1, 2012, plan sponsors of...more

Cozen O'Connor

Health Care Reform Implementation Update - July 23, 2013

Cozen O'Connor on

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

Wilson Sonsini Goodrich & Rosati

U.S. Treasury Department Delays Enforcement of Employer Mandate and Reporting Requirements Under PPACA

As seen in many mainstream press reports, the Obama administration announced in early July that (1) the employer mandate and (2) certain reporting requirements under the Patient Protection and Affordable Care Act (PPACA) will...more

Patterson Belknap Webb & Tyler LLP

IRS/Treasury Provides One-Year Delay For Certain Employer Health Coverage Reporting And Employer “Pay Or Play” Penalty Taxes

On July 9, 2013, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued formal guidance (IRS Notice 2013-45; herein, the “Notice”)1 that provides for a one year delay until 2015 with respect to (i) certain...more

Ervin Cohen & Jessup LLP

ACA Responsibility Payments, Mandatory Employer and Insurer Requirements Delayed

Those of you just arriving on the planet may have heard a little something about the Affordable Care Act and the fact that it has a lot of folks worried about just how it will all work....more

Manatt, Phelps & Phillips, LLP

Healthcare Law -- Jul 15, 2013

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

Poyner Spruill LLP

Health Care Reform Employer Mandate Delayed; DOMA Struck Down - What Now For Employers?

Poyner Spruill LLP on

Health Care Reform Employer Mandate and Reporting Provisions Delayed until 2015 - The U.S. Department of the Treasury unexpectedly announced on July 2, 2013 the delay of the employer shared responsibility ‘pay or play’...more

Orrick - Employment Law and Litigation

The Affordable Care Act – Consider Yourself on Notice

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

Mintz - Employment, Labor & Benefits...

It’s Official: IRS Issues Guidance Affirming One-Year Delay in the Affordable Care Act Employer Mandate and Related Reporting...

On July 9, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....more

FordHarrison

Legal Alert: Guidance Released On Delay Of "Pay Or Play" Penalties Under ACA

FordHarrison on

The Obama Administration has released formal guidance on the delay of the Affordable Care Act's (the "ACA") employer mandate and certain reporting requirements. ...more

Laner Muchin, Ltd.

Employers Face Compliance Options In Lights Of Delayed Implementation Of Pay Or Pay Mandate Under The ACA, But Other ACA...

Laner Muchin, Ltd. on

On July 2, 2013, the Treasury Department’s announced that enforcement of the "Pay or Play" mandate under the ACA will be delayed until January 1, 2015. This announcement was followed by a brief notice from the IRS which...more

Eversheds Sutherland (US) LLP

Legal Alert: IRS Issues Transition Relief Guidance on PPACA Reporting and Employer Penalty

On July 9, the Internal Revenue Service (IRS) released Notice 2013-45 (the Notice), granting transition relief from the “Employer Shared Responsibility” provisions and certain health plan reporting requirements under the...more

Dickinson Wright

IRS Issues Transition Relief On The One-Year Delay In PPACA’s Information Reporting And Employer Shared Responsibility Rules

Dickinson Wright on

Late on July 9, 2013, the IRS issued Notice 2013-45 which provides some additional information regarding the Department of Treasury’s recently announced delay in the information reporting and employer shared responsibility...more

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