In an effort to make up for a funding shortfall in the Commonwealth of Massachusetts’ Medicaid program, state policymakers have proposed solutions that include a “play-or-pay” option under which employers who fail to offer...more
5/30/2017
/ Children's Health Insurance Program (CHIP) ,
Deficit Reduction ,
Employee Retirement Income Security Act (ERISA) ,
Employer Contributions ,
Employer Group Health Plans ,
Health Insurance ,
Healthcare Reform ,
Medicaid ,
Pay or Play ,
Preemption ,
State Legislatures
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
2/25/2015
/ Affordable Care Act ,
Americans with Disabilities Act (ADA) ,
Cafeteria Plans ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employer Mandates ,
Equal Employment Opportunity Commission (EEOC) ,
Full-Time Employees ,
Health Insurance ,
Honeywell International ,
HSA ,
Minimum Value Plans ,
Pay or Play ,
Self-Insured Health Plans ,
Shared Responsibility Rule ,
Wellness Programs
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
12/8/2014
/ Affordable Care Act ,
Cafeteria Plans ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employer Mandates ,
Flexible Spending Accounts ,
IRS ,
Non-Discrimination Rules ,
Pay or Play ,
Public Health Service Act ,
Shared Responsibility Rule
Over the last couple of months, we have followed and reported on a particular ACA compliance strategy under which an employer subject to the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules...more
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
The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...more
While employers sometimes view the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules in isolation, they don’t operate that way. Instead, they exist side-by-side with other provisions of the Act. In...more
The IRS recently issued two Q&As on the subject of employer payment plans, the purpose of which was to again underscore that arrangements purporting to allow an employer to reimburse employees on a pre-tax basis for premiums...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
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
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
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
The Treasury Department and the IRS last week issued long-awaited final rules implementing the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules. Originally slated to take effect beginning...more
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
A recent Federal Court decision turned back a potentially debilitating challenge to the Affordable Care Act’s rules governing premium subsidies. The decision, Halbig v. Sebelius, has consequences for large employers, i.e.,...more
(Note: This is the first installment of a series of entries that Alden will be posting each week for the next 51 weeks as he counts down to the January 1st, 2015 ACA pay-or-play deadline).
...more
A little more than a month ago, the Obama administration announced a one-year delay in the enforcement of the Employer “pay-or-play” rules under the Affordable Care Act—a/k/a “ObamaCare.” Now, a handful of recent news...more
Established as a part of the comprehensive 2006 Massachusetts health care reform law, the Massachusetts Health Insurance Connector (a/k/a the “Connector”) served as a model for the American Health Benefit Exchanges that are a...more
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
In a move that took many by surprise, the Obama Administration on July 3 announced a one-year delay (to January 1, 2015 from January 1, 2014) in the enforcement of the employer mandate under the Patient Protection and...more
In a surprise announcement posted Tuesday to the White’s House website, the Obama Administration announced a one-year delay (to January 1, 2105) in the enforcement of the employer shared responsibility rules enacted into law...more
The Affordable Care Act’s employer shared responsibility rules will require large employers (50 or more full-time and full-time equivalent employees) to make an offer of minimum essential coverage to at least 95% of their...more
Under the Patient Protection and Affordable Care Act (the “Act”), the federal government, state governments, insurers, employers, and individuals all share responsibility to make affordable health insurance coverage widely...more
The core policy goals of the Patient Protection and Affordable Care Act (the “Act”)—on which there is near universal consensus—are threefold: expand health care coverage; increase the quality of medical outcomes, and reduce...more