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 »
The U.S. Departments of Labor, Treasury, and Health and Human Services have issued additional guidance on the Affordable Care Act. The guidance primarily takes the form of a new set of frequently asked questions(FAQs). The new FAQs address a variety of subjects, including: Postponement of the March 1, 2013, effective date to begin distributing [&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 »
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 »
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 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 »
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 »
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 »
The Patient Protection and Affordable Care Act requires employers to report the aggregate cost of employer-sponsored health coverage on the Forms W-2 of its employees. In March 2011, the Internal Revenue Service issued interim guidance on the Form W-2 informational reporting requirement in the form of 31 Q&As. Recently, the Internal Revenue Service revised this [&hellip… Continue Reading »
The trio of federal agencies charged with interpreting and enforcing the Affordable Care Act (ACA) and the Mental Health Parity and Addiction Equity Act (MHPAEA) have addressed some of the most significant questions arising from these laws. In a set of Answers to Frequently Asked Questions, the U.S. Departments of Treasury, Labor, and Health and [&hellip… Continue Reading »
Continuing with the recent proliferation of guidance on health care reform, the U.S. Departments of the Treasury, Labor, and Health and Human Services have released proposed regulations and requested comments regarding the implementation of a new, simplified benefit summary requirement created by the Patient Protection and Affordable Care Act (the 2010 health care reform legislation). [&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 »
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 recent health care reform legislation requires a group health plan to maintain an internal claim and appeal process that meets certain standards and to provide for an external appeal process. The U.S. Departments of Treasury, Labor, and Health and Human Services have jointly released regulations that address these subjects. Internal Claims and Appeals The [&hellip… Continue Reading »
The U.S. Departments of Treasury, Labor, and Health and Human Services have jointly released regulations that address several requirements established by the recent health care reform legislation. Most of the changes addressed by the regulations apply to plan years beginning on and after September 23, 2010. For calendar year plans, the rules take effect January [&hellip… Continue Reading »
Employers need to provide nursing mothers with a private place and break time to express breast milk. The new requirement is an amendment to the Fair Labor Standards Act (FLSA) included in the Patient Protection and Affordable Care Act, signed into law by President Obama on March 23, 2010. A new section added to the [&hellip… Continue Reading »
