Health Care Reform Dashboard

Health Care Reform Dashboard

Charting developments on the
Affordable Care Act

Employer Responsibilities

Subscribe to Employer Responsibilities RSS Feed
01/09/2015

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 »
11/03/2014

Health Plan ID Program Suspended

Late on October 31, the Centers for Medicare and Medicaid Services (CMS) Office of E-Health Standards and Services announced that it was suspending the program that required all health plans to register for a health plan ID number to be used in certain electronic transactions. This program required larger health plans to obtain a health [&hellip… Continue Reading »
10/10/2014

Health Plan ID Requirements and Other End-of-Year Considerations

Employers and other health plan sponsors may be focused on preparing for the commencement of the employer mandate under the Affordable Care Act on January 1, 2015, but a number of other deadlines and developments are emerging this autumn for plan sponsors to consider. Health Plan IDs. As we reported earlier, many health plans are [&hellip… Continue Reading »
09/04/2014

IRS Issues More Guidance on Affordable Care Act Reporting Requirements

Following up on regulations and forms published earlier this year, the IRS has issued instructions and other guidance on the shared responsibility reporting requirements under the Affordable Care Act. The new rules require: Health benefit providers, including group health plan sponsors and insurers, to provide information on an individual’s compliance with the individual mandate requirements [&hellip… Continue Reading »
08/25/2014

Government Agencies Release Further Accommodations to Organizations Opposing Mandated Contraceptive Coverage

In response to the recent U.S. Supreme Court decision in Burwell v. Hobby Lobby, Inc., the U.S. Departments of Health and Human Services (HHS) and Labor (DOL) published proposed rules on August 22, 2014, expanding the availability of the religious accommodation to the contraceptive mandate provided in their July 2013 final regulations to closely held [&hellip… Continue Reading »
07/30/2014

IRS Issues Draft ACA Reporting Forms

The Internal Revenue Service recently released draft versions of the forms that will be used to meet the shared responsibility reporting requirements under the Affordable Care Act (ACA). These draft forms have been released for comment and may not be used for filing until they are finalized. Instructions for the forms have not yet been [&hellip… Continue Reading »
07/11/2014

New ACA Shared Responsibility Reporting Requirements

Under the Affordable Care Act, employers are required to report information relating to both the employer mandate and the individual mandate. As a result of these new rules, employers will need to provide information to the government relevant to whether employers and individuals are meeting their responsibilities under these mandates. Employers also will have to [&hellip… Continue Reading »
07/11/2014

Employer Mandate Addresses Small Employers and Staffing Organizations

The final regulations on the ACA’s shared responsibility rules for employers (the “employer mandate”) established basic rules for compliance, including: Rules for determining whether the employer mandate applies A look-back measurement methodology that most employers subject to the rules will use for determining who is a full-time employee Safe harbor alternatives for determining whether coverage [&hellip… Continue Reading »
05/07/2014

New FAQs Address Effect of Affordable Care Act on COBRA and Other Matters

In a wide-ranging set of frequently asked questions (FAQs) and other guidance, the U.S. Departments of Labor, Treasury, and Health and Human Services have addressed a number of issues pertaining to the Affordable Care Act (ACA). They include issues pertaining to COBRA and the Children’s Health Insurance Program Reauthorization Act (CHIPRA), annual cost-sharing limits, preventive care, [&hellip… Continue Reading »
02/12/2014

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 »
10/25/2013

IRS Issues Proposed Regulations on Employer-Provided Health Care Coverage Reporting Requirements

The Internal Revenue Service has issued proposed regulations on reporting requirements under the Affordable Care Act (ACA). The regulations, released on September 9, 2013, address two separate ACA reporting requirements: one relating to the individual mandate and the other relating to the employer mandate. Failure to comply could result in tax penalties unless the failure [&hellip… Continue Reading »
07/03/2013

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 »
05/08/2013

DOL Releases Guidance on Employer Notices about Exchange Availability

The U.S. Department of Labor (DOL) has published guidance on the notice that most employers must provide to their employees by October 1, 2013, about the insurance that will be available through health care marketplaces known as “exchanges.” The guidance includes three model notices. Under the Affordable Care Act, employers offering health coverage must notify employees [&hellip… Continue Reading »
04/25/2013

More Guidance Issued on Summaries of Benefits and Coverage

The U.S. Department of Labor has issued a set of frequently asked questions, together with a new template, for the Summary of Benefits and Coverage (SBC) that applies to group health plans and individual health insurance. The new rules and form modify the guidance that was in effect for the first SBCs that employers needed to [&hellip… Continue Reading »
03/20/2013

Agencies Propose Regulations on the 90-Day Waiting Period Requirement

The U.S. Departments of Health and Human Services, Labor, and Treasury have released a joint set of proposed regulations implementing the requirement in the Patient Protection and Affordable Care Act that group health plans and health insurance issuers offering group health insurance cannot apply a waiting period that exceeds 90 days. The proposed regulations make the [&hellip… Continue Reading »
01/07/2013

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 »
09/06/2012

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 »
05/16/2012

New Guidance on Summaries of Benefits and Coverage

The U.S. Department of Labor (DOL) has issued additional guidance on the summaries of benefits and coverage (SBCs) that the Affordable Care Act will require many health plan sponsors to distribute as early as this fall. The guidance primarily takes the form of a new set of FAQs (frequently asked questions and answers) that supplements [&hellip… Continue Reading »
03/21/2012

Added Guidance on Summaries of Benefits and Coverage

The three agencies responsible for issuing guidance on the Affordable Care Act (ACA)—the U.S. Departments of Labor, Treasury, and Health and Human Services—have issued a new set of FAQs (frequently asked questions and answers) on the requirement to furnish summaries of benefits and coverage (SBCs) regarding group health plan coverage. The FAQs address a few [&hellip… Continue Reading »
02/14/2012

Final Regulations Address Summary of Benefits and Coverage

The Affordable Care Act (ACA) requires group health plans and health insurers to prepare and distribute a brief, uniform summary of benefits and coverage (SBC) that aims to provide individuals with a better understanding of the health coverage offered under an arrangement and a basis of comparison with other health plans and policies. The three [&hellip… Continue Reading »
.