News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Internal Revenue Service

2017 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare

by Snell & Wilmer on

As 2017 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are presenting our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 will cover...more

More Hurricane Relief & Expansion of DoL Relief to Hurricane Irma

by Winstead PC on

Leave donation program was extended to assist victims of Hurricanes Irma today. The new leave donation program permits an employee to donate his leave to a charitable organization that is eligible to receive charitable...more

IRS and DOL Provide Relief for Plan Sponsors and Participants Affected by Hurricane Harvey

by Seyfarth Shaw LLP on

The Internal Revenue Service (IRS) and Department of Labor (DOL) issued temporary relief on deadlines and procedural requirements applicable to employee benefit plans for employers impacted by Hurricane Harvey. ...more

First Round of Hurricane Harvey Relief Guidance

by Winstead PC on

No good deed goes unpunished and as soon as I hit send on the last alert on Hurricane Harvey relief, three more pieces of relief guidance relevant to employers and their employee benefit plans were released. The Internal...more

Severance Agreements – Three Tax Traps for the Unwary

by Foley & Lardner LLP on

Severance agreements – especially severance agreements for terminating executives – are ripe with potential tax planning challenges and opportunities....more

Health Care Reform in Transition While Congress Deliberates

by 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

Avoiding COBRA’s Bite: Measures to Counter COBRA Class Actions

by Perkins Coie on

With the filing of a class action complaint in late 2016 in the U.S. District Court for the Southern District of Florida, Wal-Mart Stores, Inc. became the latest large company accused of failing to provide adequate notices as...more

21st Century Cures Act Would Give Small Employers Greater Use of HRAs

by Jackson Lewis P.C. on

Passed swiftly by Congress, the 21st Century Cures Act (H.R. 34) seeks to hasten cures for killer diseases, among other things. President Obama is expected to sign the bill on Tuesday, December 13. One of those other things...more

Update on ACA Reporting (Forms 1095-C and 1094-C) – Round Two

by Poyner Spruill LLP on

The Internal Revenue Service just issued Notice 2016-70 granting certain transitional relief in regards to 2016 ACA reporting requirements. In particular this Notice: - Postpones the due date to provide 2016 Form...more

Required Reading – New Instructions for ACA Reporting

Unlike the forms for the 2015 calendar year, the 2016 Forms 1095-C must be provided to employees by January 31 and must be submitted to the IRS electronically by March 31 (for those with under 250 forms submitting on paper,...more

What is Telemedicine? A Cool Benefit or a Hot Mess?

by Snell & Wilmer on

We’ve had numerous inquiries lately about telemedicine benefits. My clients most typically ask either “is this a group health plan?” or “is it just access to another provider?” Clearly, there is much confusion surrounding...more

2016 Draft Forms 1094-C and 1095-C and Instructions: What’s New, Page-by-Page

by Balch & Bingham LLP on

In the ACA realm, change is the only constant, so don’t take this to the bank. We’re telling you what we see for the first time, on a first reading of the draft 2016 Forms and Instructions that the IRS has released since...more

ACA Reporting Update – 2016 Draft Forms & Instructions Released

Since our last ACA Reporting Update, the extended deadlines to distribute Forms 1095-B and 1095-C to covered individuals and employees and to file the forms with the IRS have passed. The IRS has stated, however, that late...more

The ERISA Litigation Newsletter - May 2016

by Proskauer Rose LLP on

Editor’s Overview - In this issue of Proskauer's ERISA Litigation Newsletter, we review a recent ruling by the Tenth Circuit Court of Appeals concerning the application of controlled group principles to the building...more

Cadillac Tax: A Levy in Limbo

by Best Best & Krieger LLP on

The future of the Cadillac tax, a key cost-control mechanism and federal revenue source enacted as part of the Patient Protection and Affordable Care Act (ACA), is unclear. Though initially set to take effect in 2018,...more

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

by McDermott Will & Emery on

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

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

by 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

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

by Franczek Radelet 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

IRS Notice 2016-4 — ACA Reporting Extension for Forms 1094 & 1095

by Dorsey & Whitney LLP on

IRS Notice 2016-4 makes for some happy reading. (IRS Notice 2016-4) - Background. All Applicable Large Employers (those with 50 or more full time equivalent employees) must report on Form 1095 whether they offered...more

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

by 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

Recent Guidance Expands on Affordable Care Act Implementation Rules

by Best Best & Krieger LLP on

Changes could have a significant impact on existing benefit programs - The IRS issued a new notice on Wednesday that provides guidance regarding aspects of Affordable Care Act implementation. The following are addressed...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

Final Forms and Instructions for ACA Information Reporting Released

by Snell & Wilmer on

The IRS recently released the final forms and instructions for information reporting under the Affordable Care Act (“ACA”). The final forms and instructions will be used for reporting in 2016 concerning 2015 coverage. The...more

Reporting for ACA Mandates: Final Forms and Additional Guidance

by 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

IRS Releases Final Forms for Health Care Reform Reporting

by Thompson Coburn LLP on

With required reporting under the Affordable Care Act (ACA) looming, employers should be aware of the latest guidance from the IRS. As a reminder, information reporting requirements apply to all employers who are members of...more

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