Summary A set of Frequently Asked Questions addresses several issues of vital interest to employers in assessing the connection between COVID-19 vaccinations and their health plans. The Upshot The FAQs confirm that the preventive care rules under the Affordable Care Act (ACA) require health plans to cover the full cost of vaccinations that have received an emergency [&hellip… Continue Reading »
The IRS has followed up on its recently proposed Health Reimbursement Arrangements (HRA) regulations with guidance on some open issues. Notice 2018-88 specifically addresses the interplay between HRAs and two Internal Revenue Code requirements: the employer mandate under the Affordable Care Act (Code Section 4980H) and the nondiscrimination rules for self-funded health plans (Code Section 105(h)). Employer [&hellip… Continue Reading »
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 »
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 »
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 »
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 »
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 »
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 »
In a series of three notices, the IRS has signaled the approach that it may take on certain key issues arising under the employer shared responsibility, or “pay or play,” provisions of the Affordable Care Act (ACA) and is seeking comment on these and other questions. All of the matters discussed in the notices will [&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 »