New Law Permits Individual Premium Reimbursement HRAs for Small Employers

A new law signed by President Obama restores the ability of small employers to reimburse employees for their individual health insurance premiums beginning January 1, 2017. The 21st Century Cures Act exempts qualified small employer health reimbursement arrangements from many of the Affordable Care Act’s (ACA) requirements. It also provides funding for medical research and […]

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 […]

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 […]

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 […]

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 […]

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 […]

No More Election-Lock for Non-Calendar Year Employer Plans

The IRS recently released welcome additions to the permitted election changes for health coverage under the IRS Code Section 125 Cafeteria Plan mid-year election change rules. The guidance, released as IRS Notice 2014-55, solves an election lock problem that has been facing employer-sponsored non-calendar year plans since the opening of the Federal Marketplace (aka Exchange). […]

HHS Approves NC Delay of Employee Choice in SHOP Exchange

On May 27, 2014, the U.S. Department of Health and Human Services (HHS) issued a final rule in an effort to move toward implementing employee choice in the Small Business Health Insurance Options Program, also known as the SHOP Exchange.  This feature allows small employers purchasing group health insurance through the SHOP Exchange to choose […]

Employers Sponsoring MEWA Plans Should Beware of ACA Non-compliance Risks

Although the employer mandate penalties of the Affordable Care Act (ACA) have been delayed until 2015, many other pieces of the ACA take effect this year, in 2014.  For example, the prohibition on pre-existing condition exclusions, the out-of-pocket limits, and the prohibition on annual or lifetime limits for essential health benefits are all effective for […]

Small employers can shop, but can’t buy, on the SHOP Exchange

Last week, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health & Human Services (HHS) announced a one year delay to the SHOP Exchange (or Marketplace). The SHOP (Small Business Health Options Program), originally scheduled to go live on October 1, 2013 with the individual marketplace, was previously pushed back to November 1.  The first delay to […]

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