As you may recall, in late September, we expected a decision from the Fifth Circuit in Texas v. United States—the case challenging the constitutionality of the Patient Protection and Affordable Care Act (ACA)—in the fall of...more
Many employers began to receive notices from the IRS in 2018 proposing the assessment of a payment against the employer for the tax years 2015 and 2016 under Section 4980H of the Internal Revenue Code. The issuance of these...more
Within the last few days, we have received a number of emails and calls from public agency clients stating that the IRS wrote them to demand an Employer Shared Responsibility Payment amounting to millions of dollars. ...more
The Patient Protection and Affordable Care Act (the “ACA”) has survived two trips to the U.S. Supreme Court. It now appears as though a third is likely....more
If you believe your company was subject to the Affordable Care Act (ACA) coverage requirements in 2015 (generally, all employers with 50 full-time or full-time equivalent employees), please take note that the Internal Revenue...more
The Internal Revenue Service (IRS) has started issuing the first wave of Letters 226-J informing applicable large employers (i.e., those employers with 50 or more full-time equivalent employees) that they may be liable for an...more
In a November 20, 2017 post, we reported on Massachusetts’ passage of H. 3822, “An Act Further Regulating Employer Contributions to Health Care,” (the “Act”), the purpose of which is to shore up the finances of the...more
It’s official. The IRS has finally begun the process of collecting penalties under the Affordable Care Act’s (“ACA”) employer shared responsibility provisions, better known as the “employer mandate.” The IRS has started...more
On November 2, 2017, the IRS issued guidance regarding the enforcement of Employer Shared Responsibility payments, otherwise known as the Section 4980H penalty. Questions 55-58 of the IRS Questions and Answers on Employer...more
As 2017 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are presenting our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 will cover...more
Individuals completing their 2016 IRS Form 1040s will recognize the question asking if they, their spouses and dependents had qualifying health care coverage in 2016 (Form 1040 line 61, Form 1040A line 38, Form 1040EZ line...more
Alden Bianchi, Chair of Mintz Levin’s Employee Benefits & Executive Compensation Practice, will provide a weekly installment on the complex reporting obligations outlined by the Affordable Care Act for health insurance...more
In our previous blog post, we evaluated the legal issues at stake in King v. Burwell. We will now examine some of the ramifications of a Supreme Court decision that goes against the Obama Administration, assuming such were to...more
Wrapping up the 2015 enrollment period, Healthcare.gov and State-based Marketplaces in seven states have announced special enrollment periods (SEPs) for people who were uninsured in 2014 and discover they owe a “shared...more
The Treasury Department announced on Tuesday, July 2, 2013, that reporting requirements and penalties imposed on large employers under the Affordable Care Act (ACA) would be delayed one year, until January 1, 2015. ...more
On July 2, 2013, the Department of the Treasury and the White House announced via social media that the employer reporting requirements and employer shared responsibility/play-or-pay penalty are being delayed until 2015. ...more
On July 2, 2013, the U.S. Department of the Treasury announced in its Treasury Notes blog that the Employer Mandate tax payment provisions and reporting requirements under the Affordable Care Act (ACA) are being delayed from...more
The Obama administration has announced that it will provide an additional year - until 2015 - before the Affordable Care Act (ACA) mandatory employer and insurer reporting requirements begin. ...more
The Obama Administration announced on Tuesday that it is delaying implementing a key component of the Affordable Care Act for a year following complaints from the private sector about reporting requirements. The so-called...more
Yesterday, the Obama administration announced that it will allow employers until 2015 before they must either provide health care coverage to employees or pay penalties under the Affordable Care Act (ACA)....more
In a surprise announcement posted Tuesday to the White’s House website, the Obama Administration announced a one-year delay (to January 1, 2105) in the enforcement of the employer shared responsibility rules enacted into law...more
On July 2, 2013, the Obama administration announced through the U.S. Department of the Treasury that the penalties for employers under the “Play or Pay Rules” will not go into effect until 2015....more
On July 2 the White House announced that it is delaying the enforcement of the employer mandate that it provide health care coverage to employees or pay a penalty (the “play or pay” provisions) until 2015....more
In a major development in the implementation of the Affordable Care Act (ACA), the Obama administration announced on Tuesday that it will delay implementation of the “employer mandate” feature of the law....more
On July 2, 2013, the Department of Treasury announced a one-year delay in the employer shared responsibility mandate under the Affordable Care Act (“ACA”) and related information reporting. Complexity Leads to Delayed...more