Three Takeaways for Group Health Plans from the Nondiscrimination Regulations

On May 18, 2016, the Office of Civil Rights (OCR) of the US Department of Health and Human Services (HHS) published final regulations implementing section 1557 of the Affordable Care Act (ACA). Section 1557 prohibits discrimination based on race, color, national origin, sex, or disability in health activities and programs that receive federal funding or […]

Managing Marketplace Notices: Action Required

Rumor has it that nearly 500,000 Marketplace Notices dated June 21, 2016 were sent to employers from the Department of Health and Human Services (HHS). If you haven’t received one already, count yourself lucky. Many employers began receiving these notices just before the July 4th holiday weekend. The notices are designed to inform an employer that an […]

What The Same-Sex Marriage Ruling Means For Health Plans

On Friday, June 26th, the Supreme Court of the United States issued a decision in Obergefell v. Hodges, holding that all 50 states must license marriages between two people of the same sex and must recognize a same-sex marriage lawfully licensed and performed out-of-state. The decision in Obergefell could have repercussions for both self-insured and […]

The ACA Survives King v. Burwell

On Thursday, June 25, 2015, the Supreme Court of the United States handed down the opinion in King v. Burwell. The majority of the Justices found that Section 36B tax credits are available to individuals in States that have a Federal Exchange. As a result, the implementation of the Affordable Care Act (ACA) continues on unimpeded, […]

King v. Burwell: What Employers Need to Know Now

A much anticipated decision from the Supreme Court of the United States in King v. Burwell is expected any day now. A decision from the Justices could maintain the status quo, upend the Affordable Care Act, or land somewhere in between – it’s anyone’s guess. In order to prepare for the onslaught of media buzz that will ensue within minutes of […]

Glimpsing the Future of the Cadillac Tax

IRS Notice 2015-16, published on February 23, 2015, addresses Section 4980I, the Excise Tax on High Cost Employer-Sponsored Health Coverage (aka the Cadillac Tax). The Notice is the first by Treasure and IRS (the Departments) on this subject, and is “intended to initiate and inform the process of developing regulatory guidance.” The Notice is not […]

Wrap Coverage Gets an Update with a Second Round of Proposed Rules

On December 19, 2014, the Departments of Labor, Health and Human Services, and Treasury (collectively, the Departments) issued proposed regulations for two circumstances in which an employer can sponsor health coverage that wraps around and supplements individual health insurance and still qualifies as an excepted benefit: (1) limited wraparound coverage offered to part-time employees with […]

Proposed Changes to the SBC – New and Improved?

On December 22nd, the Departments of Health and Human Services, Labor and the Treasury (collectively the Departments) issued regulations proposing changes to the summary of benefits and coverage (SBC) and uniform glossary requirements and templates (here). The changes proposed would be effective for plans beginning on or after September 1, 2015. The Affordable Care Act […]

Expat Plans Exempt From The ACA – But It’s Not A Free Pass

On December 16th, President Obama signed into law the Consolidated and Further Continuing Appropriations Act, 2015 (lovingly referred to as the CRomnibus bill). The main purpose of the CRomnibus bill is to fund the federal government. Nearly 90 percent of the way through the law – sandwiched between the riveting topics of “Further Continuing Appropriations […]

Health FSA contribution limit increased by $50 for 2015

The IRS loves a good Halloween spook! On the eve of Halloween, the IRS announced a number of annual inflation adjustments, including tax rate schedules and other tax changes, in Revenue Procedure 2014-61. Included among them was the first increase to employee salary reduction contributions toward health flexible spending account coverage (health FSAs). The Affordable Care […]

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