Health Care Reform Dashboard

Health Care Reform Dashboard

Charting Developments with the
Affordable Care Act and Beyond

Taxes and Fees

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Budget Deal Addresses Health Benefit Issues

The Congressional agreement that reopened the federal government for three weeks quietly addressed—at least temporarily—several high-profile issues affecting public and private health benefits. Most significantly, the new appropriations act: Delays the effective date of the so-called Cadillac Tax by two years to 2022. This Affordable Care Act (ACA) provision imposes a 40 percent tax on [&hellip… Continue Reading »

Developments in the Affordable Care Act

After a brief lull in activity, recent developments are likely to involve all three branches of government in addressing issues under the Affordable Care Act. The Legislature: It is often said that Congress rarely takes action until a crisis needs to be addressed. With the demise of this summer’s repeal and replace effort, initiatives to [&hellip… Continue Reading »

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 »

IRS Issues Second Guidance on Cadillac Tax

The Internal Revenue Service has issued a new notice addressing issues relating to future rules governing the calculation and payment of the so-called “Cadillac tax” under the Affordable Care Act. Beginning in 2018, the ACA will impose a 40 percent nondeductible excise tax on the value of group health coverage that exceeds a baseline amount [&hellip… Continue Reading »

IRS Issues Preliminary Guidance on Cadillac Tax

Yesterday, the Internal Revenue Service issued preliminary but much-anticipated guidance on the so-called Cadillac tax imposed by the Affordable Care Act (ACA). The new notice offers very few concrete answers to employer questions about how the tax is to be calculated. Mostly, the IRS identifies issues that may be the subject of future proposed regulations, [&hellip… Continue Reading »

Treasury Proposes Minimum Value Rules for Health Plans

The U.S. Department of the Treasury has published proposed regulations that provide guidance on how an employer may determine whether its group health plan provides “minimum value.” This determination is important because a large employer (generally speaking, with 50 or more full-time employees) faces a $3,000 annual penalty (under Code section 4980H(b)) with respect to each [&hellip… Continue Reading »

HHS Releases Final Regulations on the Transitional Reinsurance Fee

The U.S. Department of Health and Human Services has published final regulations that will enable plan sponsors and insurers to calculate their liability under the transitional reinsurance fee provisions of the Patient Protection and Affordable Care Act. Beginning in 2014 (and continuing for 2015 and 2016), employers and other sponsors of self-funded health plans, as well [&hellip… Continue Reading »

IRS Publishes Guidance on Health Insurer Fees

The Internal Revenue Service has issued proposed regulations on the annual fee that health insurance companies must pay under the Affordable Care Act (ACA). To fund certain health care reform initiatives, the ACA requires health insurers to pay an aggregate fee of $8 billion in 2014 and larger amounts in subsequent years. The burden is to [&hellip… Continue Reading »

IRS Issues Guidance on Fees Employers Must Pay To Fund Patient Research Institute

The Affordable Care Act (ACA) established the Patient-Centered Outcomes Research Institute and charged it with synthesizing and disseminating comparative clinical effectiveness research findings to help patients, clinicians, purchasers, and policymakers make informed health decisions. To fund this Institute, the ACA requires health insurers and self-funded group health plan sponsors to pay a fee for each [&hellip… Continue Reading »

More Guidance Provided on State Health Insurance Exchanges

Following up on guidance issued last month, the Department of Health and Human Services has proposed two new sets of regulations and the Department of the Treasury has proposed one on the state-based health insurance marketplaces known as Affordable Insurance Exchanges. (To view our alert on the earlier guidance, click here.) The Patient Protection and [&hellip… Continue Reading »

New Guidance on Health Care Reform

The three federal agencies that have published regulations on health care reform provisions (U.S. Departments of Treasury, Labor, and Health and Human Services) have furnished additional guidance on certain issues of particular importance to employers and other group health plan sponsors. A new set of Frequently Asked Questions and Answers addresses specific questions that many [&hellip… Continue Reading »

IRS Issues Guidance on Small Employer Health Insurance Expense Tax Credit

The IRS has issued a notice explaining provisions in the recently enacted health care reform legislation that establish a federal income tax credit for small employers who implement or maintain health insurance coverage for employees. The notice clarifies various aspects of the new rules, including the following: To qualify for the full tax credit, an [&hellip… Continue Reading »

Guidance Clarifies Extension of Health Coverage to Adult Children

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 »

Health Care Reform Briefing: Cutting Through the Confusion

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 »