The December Monthly Minute highlights the IRS’ decision to make permanent the ACA individual-reporting extension and EBSA’s restoration of $1.4B as a result of its FY22 enforcement actions....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
In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more
Under a common strategy for controlling group health care plan costs, employers sometimes adopt arrangements under which an employee is offered cash as an incentive to waive coverage. These arrangements are colloquially...more
On October 1, 2014, the Departments of Labor, Health and Human Services and Treasury issued final regulations that address the treatment of dental, vision and employee assistance programs (EAP) as "Excepted Benefits" under...more