Health Care Reform Dashboard

Health Care Reform Dashboard

Charting developments on the
Affordable Care Act

Employer Mandate/Shared Responsibility (Pay or Play)

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Supreme Court Upholds Affordable Care Act Subsidies in King v. Burwell

In a much-anticipated decision, the U.S. Supreme Court ruled today that individuals who enroll for coverage in a health insurance exchange may qualify for a subsidy to make that coverage more affordable, regardless of whether the exchange is established by the federal or a state government. The 6-3 decision in King v. Burwell upholds the [&hellip… Continue Reading »

Expatriate Plans Exempted from Many Affordable Care Act Provisions

In the Consolidated and Further Continuing Appropriations Act (the recently enacted federal budget bill often known as the “CRomnibus” legislation), Congress has exempted health plans designed to cover expatriates from most of the requirements of the Affordable Care Act. The exemption will generally apply where a group health plan provides significant health coverage and substantially [&hellip… Continue Reading »

Student Employees under the Affordable Care Act’s Employer Mandate

Effective January 1, 2015, colleges and universities will need to comply with the employer mandate under the Affordable Care Act, which will have particular implications involving certain student employees. The employer mandate requires large employers (defined as 50 or more full-time employees or full-time equivalents) to offer health coverage that meets certain standards or to [&hellip… Continue Reading »

Midyear Check on Health Plan Compliance

If you sponsor or administer a group health plan, you are almost certainly taking steps to prepare for legal requirements that will become effective on or before January 1, 2015. New rules under HIPAA, the Affordable Care Act (ACA), and other laws will affect your plans. As we pass the midpoint of 2014, it is [&hellip… Continue Reading »

ACA Employer Mandate Final Regulations Released; Enforcement Delays Provided for Mid-Sized Employers

Very large employers will be required to offer health care coverage to their full-time employees or pay a penalty to the federal government beginning January 1, 2015. Under the final regulations released by the U.S. Department of Treasury (Treasury Department) on February 10, 2014, however, employers with fewer than 100 full-time employees will have an extra [&hellip… Continue Reading »

Effective Date of ACA Employer Mandate (Pay or Play) is Postponed

In a startling development, the federal government appears ready to delay by one year the effective date of one of the central provisions of the Affordable Care Act (ACA)—the shared responsibility provisions (more commonly called the “employer mandate” or “pay or play”). This will give employers additional time to engage in strategic workforce planning in [&hellip… Continue Reading »

Treasury Proposes Minimum Value Rules for Health Plans

The U.S. Department of the Treasury has published proposed regulations that provide guidance on how an employer may determine whether its group health plan provides “minimum value.” This determination is important because a large employer (generally speaking, with 50 or more full-time employees) faces a $3,000 annual penalty (under Code section 4980H(b)) with respect to each [&hellip… Continue Reading »

IRS Releases Further Guidance on Employer Health Care Coverage Mandate and Penalties

The Internal Revenue Service has released proposed regulations and FAQs on the shared responsibility provisions of the Affordable Care Act (ACA). These rules require large employers to offer full-time employees and their dependents the opportunity to enroll in meaningful, affordable coverage under an employer-sponsored plan or pay a penalty. The rules are often referred to [&hellip… Continue Reading »

Guidance Issued on Essential Health Benefits and Other Individual and Small Group Market Reforms

The U.S. Department of Health and Human Services (HHS) has issued two sets of proposed regulations issued under the Affordable Care Act (ACA) that will affect the design, availability, and cost of health insurance plans, primarily in the individual and small group markets. Most significantly, HHS has published proposed regulations defining the “essential health benefits” [&hellip… Continue Reading »

Federal Agencies Issue Guidance on When Employees Must Be Allowed To Enroll in Health Coverage under Affordable Care Act Provisions

The IRS and other federal agencies have issued new guidance on when employers must allow employees to enroll for group health coverage to avoid paying penalties under the shared responsibility (also known as employer “pay or play”) provisions and comply with the waiting period requirements under the Affordable Care Act (ACA). The new rules follow [&hellip… Continue Reading »

Federal Agencies Request Comments in Advance of Health Care Reform Regulations

The U.S. Department of the Treasury has asked for public comments about potential approaches to implementing the shared responsibility (also known as employer “pay or play”) provisions of the Patient Protection and Affordable Care Act (PPACA), as well as general comments about the 90-day waiting period requirement and the relationship among the waiting periods, automatic [&hellip… Continue Reading »