As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more
On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23 – 27, 2019. September 24, 2019: The IRS issued a notice that provides a safe...more
On February 5, 2016, the Departments of the Treasury, Labor, and Health and Human Services (the Departments) issued guidance addressing the application of market reforms and other provisions of the Affordable Care Act (ACA)...more
Guidance from HHS and Treasury sets a high bar for 1332 waiver approvals; Kentuckians support Medicaid expansion and their State Marketplace despite plans to change course; and South Dakota's executive budget includes funds...more
As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more
When it comes to mergers and acquisitions involving at least one applicable large employer (ALE), the substantive rules governing employer shared responsibility (under Internal Revenue Code § 4980H) and the corresponding...more
Ever since the Treasury Department in early 2014 issued final regulations on the employer shared responsibility tax (ESR tax)1 and the related final reporting regulations (ESR regulations)2 under the Patient Protection and...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
The Treasury Department and Internal Revenue Service recently issued final regulations implementing the employer shared responsibility provisions of the Affordable Care Act. For “applicable large employers” — i.e., those with...more
As many small employers rejoice over a delayed effective date, large employers should be rolling up their sleeves to adapt their evolving shared responsibility compliance strategies for 2015 to a new final rule from the U.S....more
The Treasury Department has announced further extensions for medium-sized and large-sized employers for compliance with the “employer mandate” of the Affordable Care Act (“ACA”). The employer mandate requires employers with a...more
Last week, the Treasury Department issued a final rule, with an accompanying press release and fact sheet, in which it delayed, for a second time, the employer mandate requiring mid-size employers with 50-99 full-time...more
On February 11th, the Treasury Department issued its much-anticipated final regulations on the Affordable Care Act’s (ACA) so-called employer mandate, under which certain employers have to either (a) offer affordable,...more
Employers with 50 to 99 employees were granted a break on Monday when the U.S. Treasury Department gave them an additional year to comply with the employer mandate of the Affordable Care Act (ACA). This relief was granted as...more
Executive Summary: The Department of Treasury has posted a statement on its blog indicating that the volunteer hours of volunteer firefighters and volunteer emergency medical personnel do not need to be included in...more
In This Issue: Leading the News; Implementation of the Affordable Care Act; Other HHS and Federal Regulatory Initiatives; Other Congressional and State Initiatives; Other Health Care News; and Hearings and Mark-Ups...more
For the past several months (and, in many cases, years), most large employers have been preparing for the consequences of offering (or not offering) their workforce health coverage and complying with the complexities...more
Like many, I was initially relieved when I read the July 2, 2013, announcement by the U.S. Treasury Department, effectively providing "large" employers with up to an additional year (to 2015) to comply with the ACA's Employer...more
Although the employer mandate has been delayed to 2015, employers shouldn’t relax too much because significant planning still needs to be done now. Beginning in 2015 large employers either must offer full-time employees...more
The IRS issued Notice 2013-45 recently, the official guidance document explaining the one-year delay in the implementation of the employer pay-or-play penalties under the Patient Protection and Affordable Care Act ("PPACA")...more
On July 2, 2013, the U.S. Treasury Department delayed enforcement of the employer “play or pay” mandate penalties and reporting requirements one year to 2015, stating that covered employers should still comply with the...more
Calendar-year plans should use updated IRS Form 720 and related instructions to file by July 31 deadline. Under the Affordable Care Act (ACA), for plan years ending on or after October 1, 2012, plan sponsors of...more
With only two weeks before Congress’ August recess and just a little more than two months before October open enrollment begins, Washington is busy sorting through, implementing and, in some cases, fighting the Affordable...more
As seen in many mainstream press reports, the Obama administration announced in early July that (1) the employer mandate and (2) certain reporting requirements under the Patient Protection and Affordable Care Act (PPACA) will...more