Business Owner Charged with Fraud Connected to the Paycheck Protection Program - On June 15, 2020, the owner of several information technology companies was charged in a criminal complaint with bank fraud and for making...more
On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more
On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more
On October 22, 2018, in perhaps the most significant guidance resulting from President Trump’s 2017 Executive Order 13813, “Promoting Healthcare Choice and Competition Across the United States” (“2017 Executive Order”), the...more
In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more
On September 16, 2015, the IRS finalized these ACA coverage reporting Forms and Instructions... We report here, with minimal analysis, changes that we recognized on first comparison to the 2015 Draft Forms and Instructions....more
In a recent notice, the Internal Revenue Service has tempered prior guidance that closed the door on employer arrangements for paying the cost of individual health insurance for employees. The IRS still views these premium...more
Continuing its focus on so-called “premium reimbursement” or “employer payment plans”, the Internal Revenue Service (IRS) released IRS Notice 2015-17 on February 18, 2015. In this Notice, which was previewed and approved by...more
Some employers – particularly smaller ones – have assisted their employees to obtain health insurance by reimbursing them for the cost of insurance they purchase in the individual market. Does this practice satisfy the...more
Last week, HHS, along with the Department of Labor and the Treasury, provided long overdue guidance regarding the third category of supplemental “excepted benefits” as defined by Section 2791 of the Public Health Services...more