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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
Beginning in 2016, the Centers for Medicare & Medicaid Services (CMS) will begin its process of verifying the eligibility of recipients who receive the Affordable Care Act’s (ACA) advanced premium tax credit to help purchase...more
The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...more
In This Issue: - Labor and Employment and ERISA Class Actions After Wal-Mart and Comcast — Practice Points for Defendants (Part I – Commonality)* - Agencies Release Guidance on HRAs, FSAs, and Employer Payment...more
The Internal Revenue Service has issued proposed regulations on reporting requirements under the Affordable Care Act (ACA). The regulations, released on September 9, 2013, address two separate ACA reporting requirements: one...more
On July 2, 2013, the Treasury Department made a surprise announcement that enforcement of the Employer Shared Responsibility Mandate, a provision of the Patient Protection and Affordable Care Act ("PPACA"), would be delayed...more
Health Care Reform: IRS Transitional Relief Delays Pay or Play Reporting and Penalties - As we reported in an alert on July 3, the IRS has provided transitional relief to employers that delays pay or play reporting and...more
On July 9, 2013, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued formal guidance (IRS Notice 2013-45; herein, the “Notice”)1 that provides for a one year delay until 2015 with respect to (i) certain...more
On July 9, the Internal Revenue Service (IRS) released Notice 2013-45 (the Notice), granting transition relief from the “Employer Shared Responsibility” provisions and certain health plan reporting requirements under the...more
On the heels of last week’s announcement that the Affordable Care Act’s (ACA) reporting requirements and Play or Pay penalties will not go into effect until 2015, the IRS has released transition relief clarifying that the...more
As reported in prior Snell & Wilmer publications (See September 2011 Workplace Word, October 2011 Workplace Word and January 9, 2013 Legal Alert), there are numerous reasons why employers need to ensure that they do not treat...more
Beginning in 2014, the Affordable Care Act of 2010 (the "Act") will prohibit group health plans and group health insurers from imposing waiting periods greater than 90 days of employment....more
In This Alert: - A. What Is The Employer Shared Responsibility Penalty? - What Is The “Failure To Offer Coverage Penalty”? - How Is The “Failure To Offer Coverage Penalty” Calculated? - What Is...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 2014, certain employers may be subject to a penalty tax,...more
On January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more
In This Presentation: - Healthcare - 401(k) Plan Fee Disclosures and Fiduciary Responsibilities - Fair Labor Standards Act - Data Privacy Issues Please see full presentation below for more...more