Individual Coverage Health Reimbursement Arrangements (ICHRAs) have continued to grow in popularity since their inception in 2019 (see our article here summarizing the 2019 rule establishing ICHRAs). While initially it seemed...more
6/19/2024
/ COBRA ,
Employee Benefits ,
Health Insurance Portability and Accountability Act (HIPAA) ,
ICHRA ,
IRS ,
Medicare ,
Payment Systems ,
PCORI ,
Popular ,
Reporting Requirements ,
Small Business ,
Vendors
On January 30th, President Biden announced his intention to end both the COVID-19 national emergency and the COVID-19 public health emergency (together, the “Emergency Declarations”) effective May 11, 2023. The Emergency...more
Not surprisingly, leading up to and in the wake of the U.S. Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, our employee benefits team has been spending a lot of time helping our clients wade through...more
7/20/2022
/ Abortion ,
COBRA ,
Coronavirus/COVID-19 ,
Dobbs v. Jackson Women’s Health Organization ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Health Insurance Portability and Accountability Act (HIPAA) ,
IRS ,
Medical Reimbursement ,
Mental Health Parity Rule ,
MHPAEA ,
Pharmacy Benefit Manager (PBM) ,
SCOTUS
The Consolidated Appropriations Act, 2022, signed into law on March 15, 2022, extended relief first made available at the start of the pandemic which allowed first dollar coverage for telehealth services under a high...more
Embedded in the Consolidated Appropriations Act, 2021 (the “CAA”) is a new obligation for group health plan sponsors and insurers that provide health insurance to document that their group health plan or insurance policy...more
Last year, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued two notices that extended certain benefit plan deadlines for both employees/plan participants and for plan administrators as a result of...more
COBRA compliance requires extra attention right now. There has been a wave of litigation surrounding COBRA election notices. Regulatory agencies have extended certain COBRA deadlines due to the COVID-19 pandemic. And the...more
The IRS issued two notices on May 12, 2020, Notice 2020-29 and Notice 2020-33. These Notices provide a number of options that employers could choose to offer their employees with respect to their 2020 cafeteria plan benefits...more
Takeaway Message: The IRS has recently concluded that the Affordable Care Act’s (the “ACA”) employer mandate is an ongoing tax liability which cannot be extinguished with the passage of time. In other words, the IRS has no...more
In April 2019, the Department of Health and Human Services (HHS) released guidance indicating that a health plan must include the value of financial assistance received from a drug manufacturer (often referred to as a...more
Takeaway Message: A recent IRS notice provides a future path for employers to avoid ACA employer mandate penalties by reimbursing employees for a portion of the cost of individual insurance coverage through an...more
1/15/2019
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Employer Group Health Plans ,
Employer Mandates ,
Full-Time Employees ,
HRA ,
IRS ,
Proposed Regulation ,
Safe Harbors ,
Tax Credits ,
Wage and Hour
It’s official. The IRS has finally begun the process of collecting penalties under the Affordable Care Act’s (“ACA”) employer shared responsibility provisions, better known as the “employer mandate.” The IRS has started...more
The IRS has once again extended the deadline for furnishing to employees the applicable tax forms required by the Affordable Care Act (ACA), and will continue to provide employers with penalty relief if they make good-faith...more
The Affordable Care Act requires “applicable large employers” (generally, employers with 50 or more full-time employees and full-time employee equivalents) to provide individual statements to their full-time employees and to...more