The IRS has issued its first ACA penalty letters for tax year 2021. While employers have been forewarned, many may not be fully armed to respond in a timely and compliant manner. The IRS is making good on its promise, and...more
A recently released redacted report from the Treasury Inspector General for Tax Administration (TIGTA) offers some helpful insights for employers who may be assessed shared responsibility payments because the IRS thinks they...more
If you watch the news, you may have heard that the requirement known as the “individual mandate” under the Affordable Care Act, which generally requires that individuals either obtain health insurance or pay a penalty, was...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
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
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
As part of our ongoing series on the final regulations expanding the availability of health reimbursement accounts (“HRAs”), we discussed the newly-created Individual Coverage HRAs, which generally allow for employers to...more
Over the past several years, there has been much speculation surrounding the Patient Protection and Affordable Care Act (the "ACA"), including whether it would be repealed in full, only partially, or not at all. Despite this...more
All employers are at risk of receiving a notice from the IRS that they are liable for a penalty under the Affordable Care Act for failing to offer enough employees insurance coverage, or for failing to offer particular...more
The new Tax Cuts and Jobs Act eliminates the ACA’s individual mandate to maintain minimum essential coverage, and the penalty for failure to do so, effective in 2019. While President Trump tweeted that this “effectively...more
Within the past few weeks, IRS officials have informally indicated that the IRS would begin assessing tax penalties under the Affordable Care Act’s (ACA) employer shared responsibility. The IRS has now updated its Questions...more
Many other things being equal, the longer the sail boat, the faster it can go before its bow wave defeats further speed increase. However, as any boat approaches its “hull speed,” an increasing amount of energy is required...more
On March 6, 2017, after years of promising, GOP lawmakers in the House of Representatives introduced the “American Health Care Act” (AHCA), the first concrete legislative proposal detailing the initial provisions designed to...more
Recently proposed IRS regulations aim to clarify lingering questions about steps employers with self-insured health plans must take to collect and report the taxpayer identification number (TIN) of covered individuals in...more
As a reminder, effective January 1, 2016, employers must offer minimum essential coverage to 95% or more (up from 70% or more for 2015) of their full-time employees and their dependents each month or pay a very steep penalty....more
Even though penalties for failure to comply with Affordable Care Act (ACA) coverage requirements have been in force since January 1, 2014 for employers with 100 or more full-time equivalent employees and January 1, 2015 for...more
Even though the first year of the Affordable Care Act’s employer mandate is in effect and fully phased-in, it has been our experience that few employers have bothered to review their employee handbooks to reflect the ACA. ...more
The Affordable Care Act’s (ACA) employer shared responsibility mandate requires large employers to offer certain minimum health coverage to substantially all of their full-time employees, or potentially pay significant...more
The Affordable Care Act requires an applicable large employer to offer healthcare coverage to its full-time employees or risk paying a penalty. An employee is considered full-time for this purpose if they work at least 30...more
Unlike most other years since the Affordable Care Act (“ACA”) was passed, there are relatively few new requirements employers need to implement in connection with their health plans subject to the ACA. This Advisory...more
With the end of 2015 fast approaching, employers should be aware of certain issues under the Patient Protection and Affordable Care Act (“ACA”), the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and...more
Employers are increasingly concerned with the high cost of health care and executives in the C-Suite are beginning to take notice. The Affordable Care Act (‘‘ACA’’) required employers who sponsor group health plans to adopt a...more
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
This series is devoted principally to the reporting requirements imposed by Internal Revenue Code §§ 6055 and 6056 as added by §§ 1502 and 1514 of the Affordable Care Act (ACA), respectively. The former reports offers of...more
New study shows Marketplace premiums parallel the employer market; Montana likely to select a private insurer to administer benefits to its Medicaid expansion population; and Washington’s Exchange customers will begin paying...more