News & Analysis as of

Health Insurance Employer Group Health Plans Reporting Requirements

Verrill

RxDC Reporting in Light of June 1, 2024 Deadline and Recent PBM Litigation

Verrill on

Under the Consolidated Appropriations Act of 2021 (“CAA”), employer-sponsored group health plans, including medical-only plans, must submit information about their prescription drugs and health care spending. This submission...more

Woodruff Sawyer

Compliance Alert: Reminder: RxDC Reporting Due June 1st

Woodruff Sawyer on

As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to...more

Pullman & Comley - Labor, Employment and...

Group Health Plans and Medicare Secondary Payer Rules: Do the Mandatory Reporting Obligations Apply to You?

The Medicare Secondary Payer provisions (MSP) apply to group health plans sponsored by employers with 20 or more employees, in both the private and public sectors. MSP’s mandatory reporting requirements are designed to...more

Bradley Arant Boult Cummings LLP

Making the First “Gag Clause” Attestations: A Quick Reference Guide

Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

Verrill on

Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Stinson - Benefits Notes Blog

Departments Provide Relief for 2020 and 2021 Prescription Drug Reporting

On December 23, 2022, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) issued FAQs providing relief from prescription drug and health care spending reporting requirements. The FAQs are...more

Woodruff Sawyer

Compliance Alert: Agencies Extend RxDC Reporting Deadline to January 31, 2023

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On December 23, 2022, federal agencies released ACA and CAA Implementation FAQ Part 56, which extends the December 27, 2022 deadline for Prescription Drug Data Collection Reporting (“RxDC Reporting”) through January 31, 2023,...more

FordHarrison

Deadline for Prescription Drug and Health Care Spending Reporting

FordHarrison on

The Consolidated Appropriations Act (CAA) adopted a new prescription drug reporting mandate on November 12, 2021. The mandate requires group health plans and group health insurers to submit prescription drug and health care...more

Fisher Phillips

5 Most Important Steps for Employers Doing Their 2023 ACA Compliance Planning

Fisher Phillips on

Applicable large employers must adhere to many Affordable Care Act (ACA) rules to remain compliant regarding group health plan offerings. We offer the following checklist of the five most helpful reminders you should take...more

Woodruff Sawyer

Compliance Alert: IRS Proposes Permanent 30-day Extension to ACA Reporting Deadline

Woodruff Sawyer on

Insights December 3, 2021 /Employee Benefits On November 22, 2021, the IRS filed a Notice of Proposed Rulemaking (“Proposed Rule”) that among other things, provides for an automatic 30-day extension of the deadline for...more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - New Prescription Drug and Health Coverage Reporting Requirements

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses the Biden administration’s interim final rule that requires health plans to report prescription drug and health coverage costs and its...more

Bradley Arant Boult Cummings LLP

IRS Proposes Regulations on ACA Reporting: Good News and Bad News for Employers

The Internal Revenue Service (IRS) has published proposed regulations that, if finalized, will ease some of the requirements imposed on employers reporting offers of minimum essential health coverage, including a permanent...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

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

New Guidance Delays Some Key CAA and Other Health Benefit Effective Dates

New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly - but only slightly - more manageable heading into 2022....more

Fisher Phillips

Overview Of Employee Benefit Provisions In The Consolidated Appropriations Act

Fisher Phillips on

The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more

McAfee & Taft

IRS announces relief for certain Form 1094/1095 reporting requirements

McAfee & Taft on

In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more

Foley & Lardner LLP

IRS Says ACA’s Employer Mandate is a Forever Liability – What Should Large Employers Do Now?

Foley & Lardner LLP on

Takeaway Message: The IRS has recently concluded that the Affordable Care Act’s (the “ACA”) employer mandate is an ongoing tax liability which cannot be extinguished with the passage of time. In other words, the IRS has no...more

Epstein Becker & Green

IRS Memo Concludes No There Is Statute of Limitations for ACA Employer Mandate Penalties Under Internal Revenue Code § 4980H

The IRS Office of Chief Counsel recently issued a memo which, in a surprise to many, concluded that the filing of the Affordable Care Act (“ACA”) Forms 1094-C and 1095-C (“C Forms”) does not start the statute of limitations...more

Burr & Forman

Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row

Burr & Forman on

Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is necessary in order for the IRS to administer certain portions of...more

Jackson Lewis P.C.

Employers In Union-Related Group Health Plans Must Still Comply With ACA Reporting Requirements

Jackson Lewis P.C. on

Employers who provide health benefits to their union workforce through a multiemployer group health plan must satisfy all the Affordable Care Act (ACA) reporting requirements regarding their union employees. Employers...more

Proskauer - Employee Benefits & Executive...

IRS Extends ACA Reporting Deadline and Issues Transition Relief

The IRS has not yet finalized the ACA reporting forms (i.e., the 1094-B/C and 1095-B/C) for the 2019 tax year, so it is no surprise that the IRS issued guidance this week extending the deadline to furnish the forms to...more

Proskauer - Employee Benefits & Executive...

New Jersey Individual Mandate Requires State Filings in March 2020

The Affordable Care Act’s individual mandate (i.e., the requirement that most individuals obtain adequate health insurance or pay a penalty) is dead. A side effect of the ACA mandate’s demise is that states are beginning to...more

Kilpatrick

Group Health Plan Section 111 Reporting is Back

Kilpatrick on

Self-insured plan sponsors thought they had seen the last of Group Health Plan Section 111 Reporting in 2009, but like a character in a movie …… it’s baaaccckkk. ...more

Winstead PC

Good News on Health Coverage Reporting for 2018 Coverage

Winstead PC on

Normally, the deadline for reporting health care coverage by a self-insured medical plan or an insured plan follow rapidly after year end. In an early holiday gift, the Internal Revenue Service (the “Service”) provided an...more

Proskauer - Employee Benefits & Executive...

Massachusetts Health Insurance Responsibility Disclosure Form Must Be Filed by November 30 and Annually Thereafter

Massachusetts recently published guidance regarding its new Health Insurance Responsibility Disclosure (HIRD) annual filing, which is due for the first time on November 30, 2018 and then annually thereafter. This new HIRD...more

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