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
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
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
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
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
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
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, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....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
Late on July 9, 2013, the IRS issued Notice 2013-45 which provides some additional information regarding the Department of Treasury’s recently announced delay in the information reporting and employer shared responsibility...more
On July 2 the Obama Administration announced delays of the Patient Protection and Affordable Care Act’s (“ACA”) mandatory employer and insurer reporting requirements, and the requirement that all but the smallest employers...more
To make certain that 2013 will be as exciting as 2012, on January 2 the US Treasury issued proposed regulations under section 4980H of the Internal Revenue Code (“Code”), which was added to the Code by the Patient Protection...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
The U.S. Treasury Department recently released new guidance to assist employers (generally those with 50 or more full-time or full-time equivalent employees) in preparing and planning for the 2014 requirement to offer...more