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‘Tis the (Retail) Season, Part IV: Are Seasonal Workers Entitled to Health Care Coverage? A 2014 Update

As the holiday shopping season approaches, we are considering a number of issues that employers of seasonal workers might be facing. Primary among these is whether employers are required to provide health care coverage to...more

Identify Yourself! Deadline for Health Plan Identifiers is Fast Approaching

One of the lesser-known health plan requirements adopted by the Patient Protection and Affordable Care Act (ACA) has an initial deadline that is fast approaching, and most employers will need to take action to ensure that...more

Resistance WAS Futile—California Conforms to ACA Waiting Period Requirement

After wandering in the wilderness for a year, California has now come in from the cold and conformed its requirements for eligibility waiting periods to the federal standard adopted in the Affordable Care Act (ACA). Effective...more

California Governor Signs Bill Giving Small Businesses Extra Time To Comply With ACA

On July 7, 2014, Governor Jerry Brown signed legislation that will give small business owners additional time to comply with the Affordable Care Act (ACA). The bill takes effect immediately as an urgency statute. Senate Bill...more

Some Surprises in DOL’s Just Issued Spring 2014 Regulatory Agenda

On Friday, May 23, 2014, the White House, through its executive branch and other federal agencies, issued the Spring 2014 edition of the Semiannual Regulatory Agenda. Published twice a year, the agencies’ regulatory agendas...more

A Snake in the Grass No More? DOL Proposes New COBRA Forms

As part of its continuing efforts to update the sleepier corners of the employee benefits world to conform to the Patient Protection and Affordable Care Act (ACA), the U.S. Department of Labor (DOL) recently proposed new...more

New Opportunities For In-Plan Roth Rollovers

In furtherance of Section 902 of the American Taxpayer Relief Act of 2012 (ATRA), the Internal Revenue Service (IRS) recently issued Notice 2013-74 updating prior IRS guidance regarding so-called “in-plan” Roth conversions...more

New HIPAA Deadline Around the Corner: Be Prepared!

Don’t look now, but another HIPAA deadline is just around the corner. As we noted last month, the deadline is looming for employer-sponsored health benefit plans to come into compliance with U.S. Department of Health...more

A Check-Up for Wellness Programs–Final Wellness Regulations Issued

Since 2006, the Health Insurance Portability and Accountability Act (HIPAA) has prohibited health plans from discriminating based upon an individual’s health status. Since many modern wellness programs are expressly designed...more

Final Wellness Regulations Clarify Rules For Discounts Linked To Health Results

The Internal Revenue Service (IRS), the Department of Labor (DOL), and the Department of Health and Human Services (HHS), the three federal agencies with primary responsibility for implementing the Affordable Care Act (ACA),...more

California Weighs In on Essential Health Benefits for Group Health Plans and Insurers

As a reminder of the significant role that states will play in implementing the provisions of the Affordable Care Act (ACA), we wanted to highlight some recent legislative developments in California that will be of interest...more

Wellness Programs Receive Welcome Tune-Up Under Proposed Regulations

The regulatory log-jam in Washington seems to finally be loosening up in the aftermath of the election, and the troika of agencies primarily responsible for overseeing implementation of the Patient Protection and Affordable...more

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