Health Care Reform Dashboard

Health Care Reform Dashboard

Charting Developments with the
Affordable Care Act and Beyond

Reporting

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01/20/2022

Understanding the Mental Health Parity and Addiction Equity Act

Summary This is the second briefing in our series on the Consolidated Appropriations Act, 2021 (CAA) and transparency regulations. It concerns a new rule under the Mental Health Parity and Addiction Equity Act (MHPAEA) that requires health plans to conduct and document an analysis that compares the nonquantitative treatment limitations applicable to benefits for mental [&hellip… Continue Reading »
01/11/2022

Temporary Enforcement Policy Addresses CAA’s Health Plan Service Provider Disclosure Requirements

Summary The U.S. Department of Labor (DOL) has issued a temporary enforcement policy to address frequently asked questions about the requirement for certain service providers to disclose direct and indirect compensation data to group health plan fiduciaries under the Consolidated Appropriations Act (2021) (CAA). The Upshot The CAA’s disclosure requirement applies to entities providing brokerage or consulting services [&hellip… Continue Reading »
11/02/2021

Upcoming Compliance Deadlines for Health and Welfare Plans

Summary Throughout 2020 and 2021, employers sponsoring health and welfare plans have needed to respond to a myriad of legislative and regulatory changes arising from the COVID-19 pandemic and new health legislation. To comply with these changes, employers may need to work with their vendors, amend their plans, and take other action. In this alert, [&hellip… Continue Reading »
12/05/2019

A Little Extra: IRS Ups ACA Reporting Relief

Once again, the IRS has extended the deadline for furnishing Forms 1095-B and 1095-C to individuals. Reporting penalties will not apply to those who meet the applicable deadlines and complete the forms in good faith. The deadlines for reporting information for 2019 are: Deadline for providing Forms 1095-B and 1095-C to individuals: March 2, 2020 [&hellip… Continue Reading »
12/03/2018

IRS Extends ACA Reporting Deadline Again This Year

For the third consecutive year, the IRS has extended by 30 days the deadline for health plan sponsors to furnish Forms 1095-B and 1095-C to individuals. A 30-day extension would place the deadline on a Saturday, so this year’s reprieve will allow employers, health insurers, and other plan sponsors to distribute the forms on or [&hellip… Continue Reading »
12/26/2017

IRS Extends ACA Reporting Deadline

As it did last year, the IRS has extended the deadline for furnishing Forms 1095-B and 1095-C to individuals by 30 days. This reprieve will allow employers, health insurers, and other plan sponsors to distribute the forms on or before March 2, 2018, rather than January 31, 2018. The IRS also extends the good-faith transition [&hellip… Continue Reading »
02/17/2017

CMS, IRS Address Affordable Care Act Issues in Transition

The Centers for Medicare and Medicaid Services (CMS) and the IRS have each published guidance on matters arising under the Affordable Care Act (ACA). It is too early to tell whether these measures—some of the first guidance published under the ACA by the new administration—are singular acts or signals of guidance to come, as Congress [&hellip… Continue Reading »
01/20/2017

Health Care Reform in Transition While Congress Deliberates

Changes are imminent for the Affordable Care Act and a range of other laws and regulations affecting the health care industry. Ballard Spahr attorneys established a Health Care Reform Initiative in 2008 to monitor and analyze health care reform developments. This Health Care Reform Dashboard was a product of that initiative. We intend to continue following [&hellip… Continue Reading »
11/21/2016

IRS Extends ACA Reporting Deadline

The IRS has extended the deadline for furnishing 2016 Forms 1095-C and 1095-B to individuals by 30 days to March 2, 2017. The reprieve offers welcome relief to employers, health insurers, and other plan sponsors who would otherwise have been required to distribute these forms under the Affordable Care Act (ACA) by January 31, 2017. [&hellip… Continue Reading »
09/27/2016

Hot Topics in Employer Health Benefits

As we start looking forward to 2017, and as many employers head into annual enrollment periods this fall, it is necessary to account for changes in the law that have a significant impact on health benefit plans. This short list of significant developments may help you prepare for what is coming: Affordable Care Act (ACA) Reporting. The [&hellip… Continue Reading »
08/08/2016

IRS Proposes Adjustments in Individual Mandate Reporting

The IRS has issued proposed regulations on the individual mandate reporting requirements under section 6055 of the Internal Revenue Code. To a significant degree, the new regulations reflect guidance previously published by the IRS. Although the rules are only proposed, health plan sponsors may generally rely on them now. The new guidance addresses several discrete [&hellip… Continue Reading »
12/30/2015

IRS Extends ACA Reporting Deadlines

Recognizing that many employers and others may need additional time to prepare reports under new Affordable Care Act requirements, the IRS has announced an automatic extension automatic extension of the deadline for delivering these reports. As a result: Forms 1095-B and 1095-C for 2015 do not need to be furnished to individuals until March 31, 2016. The deadline [&hellip… Continue Reading »
12/28/2015

Further Guidance on ACA Market Reforms for Group Health Plans

Following up on the issuance of final regulations on various market reform provisions under the Affordable Care Act (ACA), the IRS has issued a notice with Questions and Answers that take a more detailed look at specific ACA issues. In particular, this notice addresses: Health reimbursement arrangements (HRAs). The guidance confirms that retiree-only HRAs may [&hellip… Continue Reading »
12/22/2015

Cadillac Tax Delayed, Made Deductible

In the first significant congressional modification of the Affordable Care Act (ACA) since its passage, the notorious “Cadillac tax” on high-cost employer health plans has been delayed two years, from 2018 to 2020.  The delay is included in the omnibus spending and tax extenders bills President Obama signed on December 22.  Delay of the Cadillac [&hellip… Continue Reading »
09/30/2015

Reporting for ACA Mandates: Final Forms and Additional Guidance

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. Forms and Instructions. The following forms are now available: Form 1094-B Form 1095-B Form 1094-C Form 1095-C Instructions for Forms 1094-B and 1095-B Instructions for Forms 1094-C and 1095-C [&hellip… Continue Reading »
05/22/2015

New Guidance on Affordable Care Act Reporting Requirements

The Internal Revenue Service has issued two lengthy sets of questions and answers on the requirement under the Affordable Care Act that employers report on their compliance with the employer mandate and employees’ qualification for exchange subsidies. The new guidance is divided into general information about the reporting rules and information about completing the actual [&hellip… Continue Reading »
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 »
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 »
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