With the 2016 employer mandate tax assessment letters hitting employer desks this week, it seems like a good time to summarize our experience with the 2015 ESRP process. ...more
There’s a comically profound scene in the second “Madagascar” movie. Penguin (management) and monkey (union) committees are negotiating a labor contract. After the monkeys seem to have secured what they want, they add a...more
Entering a football stadium many years ago, your nimble correspondent encountered unarmed security contractors wearing uniforms featuring the company logo – a big, red bull’s-eye – on the front of the baseball cap and on the...more
On November 17, the IRS published the Form that Applicable Large Employers must use to respond to IRS letters regarding proposed assessment of 2015 employer mandate taxes. Form 14764 is a paper, mail-in “ESRP Response” that...more
Just days ago, “Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act,” No. 57 read as follows:
Does the IRS expect to publish more information about the employer shared...more
That’s the title of a web page that employers may find helpful upon receipt of an IRS communication asserting liability for employer mandate taxes under Code § 4980H. It should have an official notice (“CP”) or letter...more
We don’t blame you for hearing that whenever someone warns of employer mandate taxes coming your way. Nevertheless, we’re donning the chicken suit once again to keep you aware. This time, we’ll keep it short and mainly...more
The Senate’s finest hours were not those spent in July 26, 2017 health care policy debate, which resumed July 27 at 10:00 am EDT. The bipartisan demagoguery did not diminish, but some Senators on each side rose above that...more
ACA “repeal” proposals at this point seem like zombie extras – walking dead, and none of them purports to repeal employer mandate taxes that accrued in 2015. Collection is coming; only the timing is in question.
ACV 2.0 is...more
The pundits and political partisans apparently stopped reading before the heading on page 9 of the CBO’s June 26 report on the Better Care Reconciliation Act (BCRA) Discussion Draft, “Uncertainty Surrounding the Estimates,”...more
Many other things being equal, the longer the sail boat, the faster it can go before its bow wave defeats further speed increase. However, as any boat approaches its “hull speed,” an increasing amount of energy is required...more
The “Discussion Draft” released June 22, 2017 by the Senate Budget Committee carries the House Bill number (H.R. 1628) of the American Health Care Act, and kills taxes like the House bill, but there are major differences,...more
And if you are an ACA “Applicable Large Employer” (ALE), it was.
The American Health Care Act, H.R. 1628, with last minute amendments noted in H. Rep. 115-109, passed the House of Representatives on Thursday afternoon,...more
Screenplays, new business ventures and major legislation typically have problems in Act II. Hopes were raised so high in Act I. Now, things seem to drag on and on, pointlessly. Friends tell you to give up or start over...more
The Tax Man, it turns out, also may assess you for failing to offer substantially all your full-time employees and their dependents affordable, qualifying group health coverage during 2015. We’re swamped with employer...more
On September 18, 2015, the Centers for Medicare and Medicaid Services (CMS) published a set of “Frequently Asked Questions Regarding the Federally-Facilitated Marketplace’s (FFM) 2016 Employer Notice Program.”...more
9/22/2015
/ Affordable Care Act ,
Appeals ,
Centers for Medicare & Medicaid Services (CMS) ,
Certifications ,
Department of Health and Human Services (HHS) ,
Employer Mandates ,
Federal Health Insurance Exchanges ,
Guidance Update ,
Health Insurance ,
Health Insurance Exchanges ,
Healthcare.gov ,
IRS ,
Public Health Insurance Marketplace ,
Reporting Requirements ,
Subsidies ,
Tax Credits ,
Tax Liability
On September 16, 2015, the IRS finalized these ACA coverage reporting Forms and Instructions... We report here, with minimal analysis, changes that we recognized on first comparison to the 2015 Draft Forms and Instructions....more
9/21/2015
/ Affordable Care Act ,
COBRA ,
Employer Mandates ,
Health Insurance ,
HRA ,
Insurance Industry ,
IRS ,
Medicare ,
Minimum Essential Coverage ,
Multiemployer Plan ,
Reporting Requirements ,
Required Forms ,
Self-Insured Health Plans ,
TRICARE
This seems to be a trend. ACA amendments with some bipartisan support can get done if they are buried in unrelated legislation. When the President signed H.R. 3236, the ACA employer mandate was amended to promote small...more
Absent applicable transitional relief, most of which vanishes after 2015, an ACA Applicable Large Employer that fails to offer Minimum Essential Coverage to at least 70% of its 2015 full-time employees and their dependents...more
If you had at least 50 but less than 100 full-time employees (on an aggregated basis, including full-time equivalents) in an average month in 2014, then you are an ACA “Applicable Large Employer” with ALE reporting...more
For October 1 fiscal year employers, it’s budget season. Calendar year employers aren’t far behind. Those doubting their employer mandate compliance need to accrue reserves for non-deductible assessments that the IRS may...more
6/29/2015
/ Affordable Care Act ,
Annual Assessments ,
Budgets ,
Centers for Medicare & Medicaid Services (CMS) ,
Employer Mandates ,
Full-Time Employees ,
Health Insurance ,
Healthcare.gov ,
IRS ,
State Health Insurance Exchanges ,
Subsidies ,
Tax Assessment