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Has Your Company Decided to Self-Fund its Medical Plan? Don’t Forget Privacy, Security, and Reporting Requirements.

An employer that changes its medical plan from fully insured – where the insurance company sets the terms of the policy and retains the risk that claims will exceed the premiums paid – to self-funded – where the employer is...more

What to Do if Your Company is Close to the Affordable Care Act's 50 Full-time Employee Threshold

Having recently helped a client determine if it employed on average more than 50 employees per month in a calendar year and therefore was an applicable large employer (“ALE”) subject to the Affordable Care Act (“ACA”) in the...more

Entities that are subject to the Affordable Care Act’s Nondiscrimination Rules must post notice by October 17, 2016 and implement...

In May, the Department of Health and Human Services (“HHS”) published a final rule implementing Section 1557 of the Affordable Care Act (“ACA”). The rule prohibits discrimination on the basis of race, color, national origin,...more

Refresher Course on Affordable Care Act Individual and Employer Penalties For Not Having Health Insurance

Even though penalties for failure to comply with Affordable Care Act (ACA) coverage requirements have been in force since January 1, 2014 for employers with 100 or more full-time equivalent employees and January 1, 2015 for...more

Affordable Care Act Update – Some Questions Answered, Some Relief Granted

Within the last week, there has been a flurry of activity from both Congress and the Internal Revenue Service (“IRS”) with respect to the Affordable Care Act (“ACA”). This client alert first reviews the delayed effective date...more

Employer Paid Individual Health Insurance Policies Create the Potential for Significant Penalties, But Limited Relief Is Available

Despite guidance from the Internal Revenue Service (“IRS”), the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) indicating the prohibition of the practice under the Affordable Care Act...more

Penalties and Measuring Periods for Large Employers - How to Assess Potential Liability under the Affordable Care Act

Under the Affordable Care Act (“ACA”), a large employer is subject to penalties if it fails to offer to full-time employees and their dependents health coverage or if the coverage that it offers is not affordable or does not...more

Determining if the Affordable Care Act “Play or Pay” Rules Apply to a Business

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

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