Health Care Reform Dashboard

Health Care Reform Dashboard

Charting developments on the
Affordable Care Act

Plan Design Requirements

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02/25/2015

Partial Relief for Employer Payment of Individual Insurance Premiums

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 reimbursement arrangements as group health plans that fail to meet the Affordable Care Act (ACA) prohibition against annual dollar limits [&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 »
11/05/2014

IRS Seeks to Curb Popularity of ‘Skinny’ Health Plans

The Internal Revenue Service, in Notice 2014-69, has concluded that certain unconventional group health plan designs that offer limited or no coverage for in-patient hospitalization services and/or physician services will not provide “minimum value.” Consequently, this may expose large employers to financial penalties under the Affordable Care Act’s (ACA’s) “pay-or-play” employer mandate. These plans, sometimes [&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 »
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 »
04/03/2014

IRS Issues Guidance on Health FSAs

The IRS has issued guidance on two issues affecting health flexible spending arrangements (health FSAs). The first provides guidance on how a health FSA that consists solely of amounts carried forward from the prior year (through rules issued last fall that allow up to $500 to be carried forward) may be coordinated with coverage under [&hellip… Continue Reading »
11/12/2013

Final Mental Health Parity Act Regulations Released

The Internal Revenue Service, U.S. Department of Labor, and U.S. Department of Health and Human Services have jointly released final regulations and new FAQs implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). MHPAEA provisions generally became effective for plan years beginning on or after October 3, 2009, with [&hellip… Continue Reading »
07/02/2013

Final Regulations Issued on Contraceptive Coverage, Religious Organizations

The U.S. Departments of Health and Human Services, Labor, and Treasury recently released final regulations on the exemption from providing coverage for contraceptive and certain other preventive services that is available to certain religious organizations. The final regulations apply to plan years beginning on or after January 1, 2014. The final rules adopt most of the [&hellip… Continue Reading »
06/03/2013

Final Wellness Program Nondisrimination Rules Published

The U.S. Departments of Treasury, Labor, and Health and Human Services have issued final regulations on the nondiscrimination requirements applicable to wellness programs. The new rules essentially follow the terms set forth in the proposed regulations, with several clarifications, all of which will apply to plan years beginning on and after January 1, 2014. The final [&hellip… Continue Reading »
02/26/2013

HHS Finalizes Essential Health Benefits and Related Health Plan 2014 Requirements

The U.S. Department of Health and Human Services has issued final regulations and a set of frequently asked questions and answers establishing standards for the provision of essential health benefits in the individual and small group insurance markets, both inside and outside of an Exchange. In large part, the final rules adopt standards set forth in the proposed regulations [&hellip… Continue Reading »
02/26/2013

Agencies Issue New FAQs on Affordable Care Act Issues

The U.S. Departments of Labor, Health and Human Services, and Treasury have collectively issued a new series of frequently asked questions and answers primarily directed toward preventive care issues. The new FAQs address a range of specific issues relating to the requirement that health plans (other than grandfathered plans) make coverage for preventive care available without [&hellip… Continue Reading »
02/05/2013

Expanded Contraception Coverage Exemption for Religious Organizations Proposed by HHS and IRS

The U.S. Departments of Health and Human Services and Treasury have released proposed regulations, a fact sheet, and a press release on the Affordable Care Act contraceptives coverage under Women’s Preventive Health Services and the exemption for religious organizations. This proposal, issued on January 30, 2013, attempts to accommodate religious employers’ objections to all or some [&hellip… Continue Reading »
11/29/2012

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 »
11/27/2012

Proposed Regulations Address Discrimination in Wellness Programs

The Departments of Treasury, Labor, and Health and Human Services have issued a revised set of proposed regulations for nondiscrimination in wellness programs. The regulations prohibit a wellness program offered as part of a health plan from discriminating against individuals on account of an adverse health factor. The revised rules are scheduled to apply in [&hellip… Continue Reading »
05/31/2012

IRS Issues Guidance on $2,500 Health FSA Contribution Limit

The Affordable Care Act (ACA) imposes an annual $2,500 limit on the amount of salary reduction contributions that an employee may make to a health flexible spending account (Health FSA). This limit applies to tax years beginning after December 31, 2012, and is indexed for inflation in ensuing years. In a recently issued notice, the [&hellip… Continue Reading »
02/27/2012

HHS Releases FAQs on Essential Health Benefits

On February 17, 2012, the U.S. Department of Health and Human Services (HHS) released a set of FAQs concerning the Essential Health Benefits Bulletin it issued on December 16, 2011. The FAQs offer new guidance and raise new questions about the scope of what is considered an essential health benefit (EHB) for purposes of applying [&hellip… Continue Reading »
01/19/2012

Health and Welfare Benefits in 2012

Although the pace of new legislation affecting health and other welfare benefits has slowed after the first two years of the Obama Administration, plan sponsors will find no shortage of developments to monitor and implement in 2012. This alert provides a very brief review of recent developments and matters to watch in the new calendar [&hellip… Continue Reading »
08/26/2011

HHS Provides Temporary Relief for Stand-Alone HRAs

Continuing the furious pace with which it has been issuing health care reform guidance, the U.S. Department of Health and Human Services (HHS) has indicated that all health reimbursement accounts (HRAs) that were in effect before September 23, 2010, are exempt from the Patient Protection and Affordable Care Act’s prohibition against annual limits for plan [&hellip… Continue Reading »
08/05/2011

Additional Guidelines Issued on Health Plan Coverage for Women’s Preventive Health Care

The federal Health Resources and Services Administration (HRSA) has endorsed new guidelines for the coverage of women’s preventive health care services applicable to group health plans. Although many group health plans already cover a range of women’s preventive health care services, employers and other plan sponsors will need to assess the scope of their plans’ [&hellip… Continue Reading »
06/27/2011

Amendments Made to Claim and Appeal and External Review Rules

The U.S. Departments of Treasury, Labor, and Health and Human Services have collectively released amended interim final regulations addressing internal claims and appeals and the external claims review requirements under health care reform. The new regulations amend initial claims review guidance issued by the Departments on July 22, 2010. (Click here to read our legal [&hellip… Continue Reading »
06/20/2011

HHS Changes Annual Limit Waiver Procedure for Mini-Med Plans

On June 17, 2011, the U.S. Department of Health and Human Services (HHS) announced new procedures for health plans with limited benefits (including so-called “mini-med” plans) to obtain temporary waivers of the restrictions on annual dollar limits that were imposed by the Patient Protection and Affordable Care Act. Employers may adopt mini-med and similar health [&hellip… Continue Reading »
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