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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 »
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 »
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 »
The Internal Revenue Service has issued long-awaited guidance on a new requirement that employers report the cost of employee health coverage on Forms W-2. The goal of this Patient Protection and Affordable Care Act requirement is to provide useful and comparable consumer information to employees. The IRS guidance sets forth specific rules for reporting health [&hellip… Continue Reading »
Facing the application of new nondiscrimination rules imposed by national health care reform legislation, insured health plans have been granted a reprieve. According to IRS Notice 2011-1, the government agencies responsible for administering the health care reform law (U.S. Departments of Treasury, Labor, and Health and Human Services) have agreed to delay enforcement of the [&hellip… Continue Reading »
The U.S. Department of the Treasury has revised its previously issued regulations on health plans that are “grandfathered” from certain health care reform requirements. Specifically, a group health plan does not lose its grandfathered status solely due to the issuance of a new health insurance policy, either as a renewal of an existing insurance policy [&hellip… Continue Reading »
Today, the IRS released Notice 2010-62, which provides that employers will not be required to report the cost of group health plan coverage on Form W-2 issued for 2011. Employers will welcome this notice, which will allow them additional time to modify their payroll systems and procedures to address this new health care reform reporting [&hellip… Continue Reading »
The U.S. Departments of Treasury, Labor, and Health and Human Services have released guidance on how employer-sponsored self-funded group health plans can satisfy the new external claims review requirements arising from the federal health care reform legislation. The new guidance, which supplements initial claims review guidance issued by the Departments on July 22, 2010, is [&hellip… Continue Reading »
The wait is over for the estimated 2.2 million health plans hoping to qualify for grandfathered health plan status under the recently enacted health care reform legislation. Today, the three primary agencies charged with regulating and enforcing the federal government’s health care reform effort (Department of Treasury, Department of Health and Human Services, and Department [&hellip… Continue Reading »
In the first of what promises to be an ongoing series of tri-agency regulations, the Departments of Health and Human Services, Labor, and the Treasury have issued rules on one of the most controversial provisions in the health care reform legislation―the extension of coverage for children up to age 26. The guidance clarifies several key [&hellip… Continue Reading »
Employers must move quickly after the release yesterday of the U.S. Department of Health and Human Services’ first set of regulations under the health care reform law. The regulations provide guidance on the Early Retiree Reinsurance Program, which will reimburse employers and other plan sponsors for part of the costs incurred in providing group health [&hellip… Continue Reading »
Today the IRS issued the first installment of what is expected to be an avalanche of guidance on the new health care reform law. The guidance confirms that an employer-sponsored health plan may provide coverage free from federal income tax to an employee’s children up to age 27. This exclusion applies regardless of whether the [&hellip… Continue Reading »
The newly enacted health care reform bill has fueled numerous questions by employers seeking direction on arguably the most important workplace decisions they will make in the next few years. Employers need to understand the issues and recognize the decision points and their ramifications. Jean C. Hemphill and Brian M. Pinheiro have identified frequently asked [&hellip… Continue Reading »
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