On December 20, President Trump signed the Further Consolidated Appropriations Act, 2020 (the “Act”), a year-end spending bill that includes key provisions that will affect employer-sponsored benefit plans. This legal alert...more
1/3/2020
/ Affordable Care Act ,
Appropriations Bill ,
Cadillac Tax ,
Employer Group Health Plans ,
Federal Funding ,
Health Insurance ,
Medical Devices ,
Medical Leave ,
Paid Family Leave Law ,
Paid Leave ,
PCORI ,
Repeal ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders
On November 15, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Agencies”) issued a proposed "Transparency in Coverage" rule that would require most...more
12/4/2019
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Corporate Counsel ,
Cost-Sharing ,
Employer Group Health Plans ,
Executive Orders ,
Health Care Providers ,
Proposed Rules ,
Regulatory Agencies ,
Self-Insured Health Plans ,
TPAs ,
Transparency
On December 14, 2018, a Texas District Court ruled that the Affordable Care Act’s (ACA) requirement that certain individuals maintain a minimum level of health coverage, often referred to as the “Individual Mandate,” is...more
1/7/2019
/ Affordable Care Act ,
Appeals ,
Constitutional Challenges ,
Department of Homeland Security (DHS) ,
Employer Group Health Plans ,
Health Insurance ,
Individual Mandate ,
Internal Revenue Code (IRC) ,
Stays ,
Tax Cuts and Jobs Act ,
Trump Administration
On June 21, 2018, the Department of Labor (DOL) issued final regulations establishing alternative criteria under section 3(5) of the Employee Retirement Income Security Act of 1974 (ERISA) for forming single-employer...more
The stopgap government funding bill passed by Congress on January 22 included a two-year delay of the Affordable Care Act’s excise tax on high cost employer-sponsored health coverage, commonly referred to as the “Cadillac...more
This ACA Brief is the sixth in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that impact large employer-sponsored health plans.
Early Friday morning,...more
This ACA Brief is the fourth in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that affect large employer-sponsored plans.
On March 6, 2017, the U.S....more
This ACA Brief is the third in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that impact large employer-sponsored plans.
As detailed in Sutherland’s...more
This ACA Brief is the second in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that impact large employer-sponsored plans.
On January 20, President...more
This ACA Brief is the first in a series of installments that will closely track congressional and administrative actions relating to ACA provisions that impact large employer-sponsored plans.
On January 12, the U.S....more
The Consolidated Appropriations Act to fund the government through 2016 was passed and enacted on December 18. The law contains a number of benefits-related provisions, including a two-year delay of the 40-percent excise tax...more
In a 6-3 decision on June 25, 2015 in King v. Burwell, the U.S. Supreme Court held that tax credits are available under the Patient Protection and Affordable Care Act (Affordable Care Act or PPACA) to all eligible Americans,...more
6/29/2015
/ Affordable Care Act ,
Chevron Deference ,
Health Insurance ,
Health Insurance Exchanges ,
Individual Mandate ,
IRS ,
King v Burwell ,
SCOTUS ,
State Health Insurance Exchanges ,
Statutory Interpretation ,
Subsidies ,
Tax Credits
In 2014, the Department of Labor (DOL) maintained a diminished program of advance guidance under the Employment Retirement Income Security Act of 1974, as amended (ERISA), in response to requests from the regulated community....more
On Friday, the U.S. Supreme Court announced that it would review the U.S. Court of Appeals for the Fourth Circuit’s decision in King v. Burwell. In that case, the Fourth Circuit held that tax credits for health insurance...more
11/12/2014
/ Affordable Care Act ,
Employer Mandates ,
Halbig v Burwell ,
Health Insurance ,
Health Insurance Exchanges ,
IRS ,
King v Burwell ,
Popular ,
SCOTUS ,
Subsidies ,
Tax Credits
The Internal Revenue Service (IRS) recently issued Notice 2014-49 which describes a proposed approach for determining an employee’s full-time or part-time status for purposes of the employer shared responsibility rules under...more
The Internal Revenue Service has issued Notice 2014-55 to permit new health plan elections in two situations where they were not previously allowed. ...more
Two federal appeals courts issued conflicting rulings on July 22 on whether individual premium subsidies under the Patient Protection and Affordable Care Act (PPACA) are available in 36 states that have federally run...more
With the first month of the year behind us, this report outlines major insurance topics that we will be watching throughout 2014.
Forces, trends and events that we believe will affect regulation, transactions and...more
On July 9, the Internal Revenue Service (IRS) released Notice 2013-45 (the Notice), granting transition relief from the “Employer Shared Responsibility” provisions and certain health plan reporting requirements under the...more
7/12/2013
/ Affordable Care Act ,
Deadlines ,
Delays ,
Employer Mandates ,
Healthcare ,
IRS ,
Pay or Play ,
Penalties ,
Shared Responsibility Rule ,
Transition Relief ,
U.S. Treasury
On July 2, 2013, the Obama administration announced that it will delay enforcement of the employer shared responsibility penalties under the Patient Protection and Affordable Care Act (PPACA) until 2015. The one-year...more
The Internal Revenue Service (IRS) has released proposed regulations on the health insurer fee under section 9010 of the Patient Protection and Affordable Care Act (PPACA). The regulations, which were published in the Federal...more