Obamacare Provision Requiring Businesses to Provide Health Insurance Delayed Until 2015
The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other...more
The IRS has announced its next steps regarding the Employer Shared Responsibility Payments (the “ESRPs”), which are the ACA penalties assessable to “Applicable Large Employers” for failing to provide affordable health care...more
Proskauer’s 21st Annual Trick or Treat Seminar was held on Thursday, October 27. The Seminar discussed: Best Practices for Document Retention: One Size Does Not Fit All...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
The Internal Revenue Service, in Notice 2014-69, has concluded that certain unconventional group health plan designs that offer limited or no coverage for in-patient hospitalization services and/or physician services will not...more
While employers sometimes view the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules in isolation, they don’t operate that way. Instead, they exist side-by-side with other provisions of the Act. In...more
The IRS recently issued two Q&As on the subject of employer payment plans, the purpose of which was to again underscore that arrangements purporting to allow an employer to reimburse employees on a pre-tax basis for premiums...more
Health & Welfare Plans - July 1 Deadline to Begin Measuring Employee Hours for ACA Employer Mandate/“Pay or Play” - As we have discussed in many previous alerts, the Affordable Care Act’s employer shared...more
As almost all employers know, one of the many requirements of health care reform is the so-called employer mandate. The employer mandate generally provides that large employers who fail to offer their full-time employees...more
Beginning in 2015, an employer that employed at least 100 full-time employees (or full-time equivalents) during 2014 will become subject to the shared responsibility (employer mandate) provisions of the Patient Protection and...more
Particularly with the issuance of final regulations under the Affordable Care Act’s employer shared responsibility rules, employers have been concerned—justifiably—with the pay-or-play penalties. ...more
Distinguishing employees who are full-time from those who are not takes up a good deal of real estate in final regulations published in the Federal Register on February 12 implementing the Act’s employer shared responsibility...more
On February 10, 2014, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). The final regulations...more
In a move that will not come as a surprise to anyone who has been following the rocky implementation of the Affordable Care Act (“ACA”), the Obama Administration has yet again delayed important provisions of the ACA. In a...more
The Affordable Care Act added the so-called “Play-or-Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2015, certain employers, referred to as “applicable large...more
Health & Welfare Plans - Health Care Reform: IRS Issues Final ACA “Pay or Play” Regulations - The IRS issued final regulations regarding the employer shared responsibility provisions under the Affordable Care...more
So much attention has been paid to the issuance of the final employer shared responsibility regulations that some might have missed the news that final regulations were recently issued under another of the Affordable Care...more
In This Issue: Implementation of the Affordable Care Act; Other Federal Regulatory Initiatives; Other Congressional and State Initiatives; and Hearings and Mark-Ups Scheduled. Excerpt from Implementation of the...more
In last week’s post on the topic of the recently issued final regulations under the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules, we suggested that the final regulations broke little new...more
Employers in all industries are well aware of the complexities of the Affordable Care Act, and the seemingly constant barrage of guidance that interprets the health care reform requirements that apply to them. We have a...more
Early this week the Internal Revenue Service and Department of Treasury (the “IRS”) issued the first piece of the Affordable Care Act (“ACA”) penalty imposition jigsaw puzzle. It then followed up with 46 FAQs on the same...more
Executive Summary: Under final regulations issued by the U.S. Treasury Department on February 10, 2014, employers with at least 50 but fewer than 100 employees will not be required to comply with the employer shared...more
On February 10, 2014, the Internal Revenue Service released final regulations pertaining to the Employer Shared Responsibility Mandate (commonly referred to as "Pay or Play") of the Patient Protection and Affordable Care Act...more
Earlier this week, the IRS issued final regulations that provide additional guidance on the new “pay or play” rules (also called the employer shared responsibility rules) that will generally apply to employers’ group health...more
Recently issued final regulations on the employer pay-or-play rules under the Affordable Care Act (ACA) clarify the requirement that employers provide health coverage to full-time employees and their dependents, or pay a...more