News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Patient Protection and Affordable Care Act (PPACA) Health Reimbursement Account

Holland & Knight LLP

Health Reimbursement Arrangements: An Option for Small Employers

Holland & Knight LLP on

Though the employer shared responsibility provisions of the Patient Protection and Affordable Care Act (PPACA) do not apply to small employers (generally, employers with fewer than 50 full-time equivalent employees), many...more

Mintz - Employment Viewpoints

Post-Dobbs Abortion-Related Travel Benefits: Surveying Employers’ Options

In a previous post, we reported on the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization which reversed Roe v. Wade, and renders a woman’s right to make decisions regarding, and seek medical treatment...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations Part 4: Excepted Benefit HRAs

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) have expanded the use of health reimbursement arrangements (“HRAs”), including permitting the use of HRAs to...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New HRA Rules: What Employers Need to Know

Starting in 2020, employers will be able to offer health reimbursement arrangements (HRAs) that work in conjunction with individual coverage or Medicare without running afoul of the Affordable Care Act’s (ACA) market reform...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 2 – ERISA Implications

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services have expanded the use of health reimbursement accounts (“HRAs”) by allowing reimbursements for individual market insurance premiums....more

Burr & Forman

What the HRA is going on with HRAs?

Burr & Forman on

On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

Mintz - Employment Viewpoints

Agencies Issue Final Regulations Expanding Access to Health Reimbursement Arrangements

On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more

Foley & Lardner LLP

Final Regulations Permit Employers to Reimburse an Employee’s Costs for the Purchase of an Individual Health Insurance Policy

Foley & Lardner LLP on

Effective January 1, 2020, employers may put aside pre-tax funds into a health reimbursement arrangement (“HRA”) that can be used by an employee to pay for premiums and other out-of-pocket costs related to the purchase of an...more

Snell & Wilmer

Zombie Benefits – Are Health Reimbursements Arrangements (“HRAs”) Back From the Dead?

Snell & Wilmer on

The Affordable Care Act (“ACA”) has not been kind to health reimbursement arrangements (“HRAs”). Many employers got rid of HRAs, or integrated them with a major medical plan, in order to avoid significant penalties under the...more

Ballard Spahr LLP

Health Care Reform in Transition While Congress Deliberates

Ballard Spahr LLP on

Changes are imminent for the Affordable Care Act and a range of other laws and regulations affecting the health care industry. Ballard Spahr attorneys established a Health Care Reform Initiative in 2008 to monitor and analyze...more

Stinson - Benefits Notes Blog

New Law Permits Stand-Alone Health Reimbursement Arrangements (HRAs) For Small Employers

On December 13, 2016 President Obama signed into law the 21st Century Cures Act. The law had been approved with bipartisan support in the House by a vote of 392 to 26 and in the Senate by a vote of 94 to 5. The law addresses...more

McDermott Will & Emery

Recent Government-Issued FAQs Clarify ACA Employer Mandate, Market Reforms

Notice 2015-87 (the Notice) provides recent government guidance on the Affordable Care Act (ACA) employer mandate and market reforms. The Notice contains 26 frequently asked questions (FAQs) from the Internal Revenue Service...more

Snell & Wilmer

If You Blinked You Might Have Missed Important Affordable Care Act Guidance

Snell & Wilmer on

Notice 2015-87 issued by the IRS on December 16, 2015, provides guidance on numerous Affordable Care Act provisions. Below are some of the highlights....more

Franczek P.C.

IRS Issues New Guidance on ACA and Other Health Plan-Related Legal Requirements

Franczek P.C. on

In Notice 2015-87 the Internal Revenue Service (IRS) issued guidance on various health plan-related topics, including: (1) treatment of employer-provided opt-out payments for purposes of affordability under the Affordable...more

Dickinson Wright

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

Dickinson Wright on

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

Ballard Spahr LLP

Reporting for ACA Mandates: Final Forms and Additional Guidance

Ballard Spahr LLP on

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

Balch & Bingham LLP

Final 2015 Forms 1094-B, 1095-B, 1094-C, 1095-C and Instructions

Balch & Bingham LLP on

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

Franczek P.C.

Employee Benefits Alert - August 2015

Franczek P.C. on

Retirement Plans - IRS Issues Guidance on Benefit Suspension Voting under MPRA - As we have written in prior alerts, the Multiemployer Pension Reform Act of 2014 (MPRA) permits trustees of financially troubled...more

Morgan Lewis

Group Health Plans: Year-End Action Items and Upcoming Changes

Morgan Lewis on

Group health plan sponsors turn their attention to completing 2013 tasks, implementing upcoming 2014 changes, preparing for the ACA Shared Responsibility requirement in 2015, and documenting recent extensive plan changes....more

Morgan Lewis

PCOR Trust Fund Fee Due Soon for Many Plans

Morgan Lewis on

Calendar-year plans should use updated IRS Form 720 and related instructions to file by July 31 deadline. Under the Affordable Care Act (ACA), for plan years ending on or after October 1, 2012, plan sponsors of...more

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