ACA Automatic Enrollment Requirement Repealed

On November 3, President Obama signed the Bipartisan Budget Act of 2015 (H.R. 1314), resulting in a repeal of the Patient Protection and Affordable Care Act’s (PPACA) automatic enrollment requirement for employers with 200 or more full-time employees. The Bipartisan Budget Act of 2015 repeals Section 18A of the Fair Labor Standards Act (FLSA), which was […]

Employers Finalize Preparations for ACA Reporting

On September 16, 2015, the Internal Revenue Service (IRS) finalized the forms and instructions for compliance with the ACA’s new reporting requirements under Code 6055 and 6056, also known as Minimum Essential Coverage (MEC) reporting. Want to take a gander at the final forms and instructions? You can find them here: Form 1094-B Form 1095-B […]

Preparing for 2018: New Cadillac Tax Highlights for Employers

The Internal Revenue Service (IRS) continues to rev their regulatory engine as the agency proceeds with implementation of the excise tax on high cost health coverage, otherwise known as the Cadillac Tax. The Cadillac Tax is a 40% excise tax on health coverage exceeding certain thresholds ($10,200 for self-only coverage, $27,500 for coverage other than self-only) […]

Agencies Clarify Preventive Services for Health Plans

In a joint FAQ published May 11, 2015, the Departments of Labor (DOL), Health and Human Services (HHS), and Treasury (collectively, the Departments) clarified the Patient Protection and Affordable Care Act’s (PPACA) requirement to cover preventive services without cost sharing under non-grandfathered health plans sold in the individual and group markets. Effective for plans renewing […]

In the AIR Tonight: First Look at New ACA E-Filing System

UPDATE: The IRS continues to post information about AIR. To view all of the resources currently available about AIR, click here. There is also an AIR working group. For more information about the working group meetings and presentation materials for the working group, click here. Information regarding the new reporting requirements for self-insured plans and […]

EEOC Issues Proposed Rule for Wellness Programs

At long last (and after much grumbling in Congress), the Equal Employment Opportunity Commission (EEOC) has issued proposed regulations clarifying the definition of “voluntary” in the context of wellness programs under the Americans with Disabilities Act (ADA). The ADA governs employee health programs that include disability-related inquiries or medical examinations and requires that such programs […]

Better Late Than Never? IRS Provides Limited Relief for Some HRAs

Adding to other Agency guidance on HRAs, premium reimbursement arrangements, and employer payments plans, the Internal Revenue Service (IRS) published Notice 2015-17 on February 18, 2015. This Notice clarifies earlier guidance and provides limited transition relief in specific circumstances, namely for small employers who have continued to reimburse individual policies. Such arrangements are an important […]

IRS Publication 5187: What’s New for 2014 Tax Returns

UPDATE: On February 4, 2015, the IRS made available a document identifying best practices regarding the Individual Mandate for tax return preparers. This document may be found here. Why is this important for employers? If an individual did not have qualifying health coverage for themselves or any dependents for the full calendar year, the IRS […]

New ACA Affordability Rules Impact Cafeteria Plan Flex Credits

Just before Thanksgiving, the Internal Revenue Service and Treasury released a final rule on Minimum Essential Coverage and Other Rules Regarding the Shared Responsibility Payment for Individuals, otherwise known as the individual mandate. At first glance, this final rule appears to address issues only relevant to individuals.  However, within the final rule, the IRS and […]

UPDATE: SCOTUS to Hear Challenge to Health Law’s Insurance Subsidies

On Friday, November 7, 2014, the United States Supreme Court decided to hear King v. Burwell, a case appealed from the United States Court of Appeals  for the Fourth Circuit challenging the ability of the government to provide tax subsidies for health insurance coverage purchased through federally-facilitated health insurance marketplaces. This development came as a surprise to […]

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