Obamacare Provision Requiring Businesses to Provide Health Insurance Delayed Until 2015
The Affordable Care Act or ACA (a/k/a “Obamacare”) is not dead, yet. Employers are starting to receive letters from the IRS notifying them that they owe assessable payments (“penalties”) under the employer shared...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
Some employers have attempted to manage their risks related to the employer shared responsibility tax (a/k/a the pay or play penalty) by placing employees into classifications and indicating that particular classifications of...more
Most employers are by now well aware of the “pay or play” penalties that may apply if the employer fails to offer coverage to substantially all of its full-time employees or offers coverage that fails to be affordable for...more
On December 16, 2015, the IRS issued Notice 2015-87 (the "Notice"), which provides "question-and-answer" guidance regarding how various Affordable Care Act (the "ACA") provisions apply to employer-provided group health plans....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
On June 25, 2015, the U.S. Supreme Court issued its decision in King v. Burwell, ruling that Section 36B of the Patient Protection and Affordable Care Act (“ACA”) authorizes insurance exchanges run by the federal government...more
Since its enactment in 2010, the Affordable Care Act (ACA) has generated debate and questions about the law's impact on third-party staffing arrangements. With the effective date of the ACA's "pay-or-play" employer mandate...more
As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more
On January 1, 2015, employers with 100 or more "full-time equivalents" will be subject to the "Pay or Play" regulations under the Affordable Care Act ("ACA"). Over the past few years, many consultants have sought to identify...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
The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...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
Earlier this year, 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”). We issued a Client...more
With the effective date of the “pay-or-play” employer mandate just over the horizon, employers who sponsor group health plans are well aware of the layers of complexity presented by the mandate. One of the layers that...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
January 1, 2015 is fast approaching, and with it, the first year the employer mandate applies to employers with 100 or more full-time employees (50 in 2016) – the “Play or Pay” rules. In preparation for this new law,...more
Earlier this year, the IRS issued final regulations that provide additional guidance on the employer shared responsibility rules (also called the “pay or play” rules) that will generally apply to employers’ group health plans...more
In February, the Internal Revenue Service (the "IRS") issued final regulations under Section 4980H of the Internal Revenue Code (the "Code"), which establishes the employer "shared responsibility" (or "pay-or-play") mandate...more
The Patient Protection and Affordable Care Act (“ACA”) imposes significant new reporting requirements on employers providing self-insured group health coverage to their employees and employers subject to the shared...more
Now that the IRS has issued final regulations under Section 4980H, the so-called “pay or play” provision of the Affordable Care Act, employers are deciding how to determine whether employees are full-time (30 hours or more a...more
On March 5th, 2014, the Treasury Department and the IRS issued two final reporting rules of critical importance to employers...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
Plan sponsors now have the final piece of the puzzle needed to finalize their 2015 pay-or-play strategies. The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently issued the highly...more