Originally published in February 2025, this updated report provides new material on physician practice management (PPM) arrangements, reference-based pricing arrangements, minimum essential coverage (MEC) and MEC+ plans, and...more
The Internal Revenue Service (“IRS”) released final regulations... that permit employers to set aside pre-tax funds into health reimbursement arrangements (“HRAs”) that can be used by employees to pay for premiums and other...more
In a 2-1 decision, the Fifth Circuit Court of Appeals has upheld a district court ruling that the individual mandate under the Affordable Care Act is unconstitutional. However, the Fifth Circuit has sent the case back to the...more
On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more
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
Until very recently, employers were at risk of receiving steep fines if they reimbursed employees for non-employer sponsored medical care – the Affordable Care Act (ACA) included fines of up to $36,500 a year per employee for...more
The IRS has issued proposed regulations on the individual mandate reporting requirements under section 6055 of the Internal Revenue Code. To a significant degree, the new regulations reflect guidance previously published by...more
Expatriate health plans have been surprisingly difficult to reconcile with the Affordable Care Act (ACA). Proposed regulations set to take effect in 2017 provide some useful guidance to U.S. employers that sponsor expatriate...more