As applicable large employers grapple with the Affordable Care Act’s (ACA) employer shared responsibility (pay-or-play) rules, two questions arise with notable frequency...more
12/8/2014
/ Affordable Care Act ,
Cafeteria Plans ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employer Mandates ,
Flexible Spending Accounts ,
IRS ,
Non-Discrimination Rules ,
Pay or Play ,
Public Health Service Act ,
Shared Responsibility Rule
Whether an employer makes the requisite offer of group health plan coverage is critical to the application of the Affordable Care Act’s employer shared responsibility rules as reflected in final implementing regulations...more
The Departments of the Treasury/IRS, Labor and Health and Human Services (the “Departments”) recently issued a final regulation under the 90-day waiting period limitation, which is included among the Affordable Care Act’s...more
6/30/2014
/ Affordable Care Act ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Employer Mandates ,
Healthcare ,
Healthcare Reform ,
Internal Revenue Code (IRC) ,
IRS ,
PHSA ,
U.S. Treasury
In last week’s post, we examined the appropriateness of capping the annual hours of new “variable hour employees” as a way to limit exposure under the Affordable Care Act’s employer shared responsibility rules. (These rules...more
The Affordable Care Act (the “Act”) generally prevents an otherwise eligible employee (or dependent) from having to wait more than 90 days before coverage becomes effective under a group health plan. The regulation of waiting...more
Introduction -
A recent decision by the U.S. Court of Appeals for the First Circuit increases the risk that a private equity fund could be liable for its portfolio company’s unfunded pension liabilities. Additionally,...more
A May 10 Wall Street Journal article, “Employers Eye Bare-Bones Health Plans Under New Law” (see the associated video on WSJ Live), highlighted a compliance strategy to minimize employer exposure for assessable payments under...more
As we have reported in this blog, the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently released final regulations containing modifications to the HIPAA Privacy, Security, Enforcement, and...more
2/18/2013
/ Business Associates ,
Cloud Computing ,
Covered Entities ,
Data Breach ,
Department of Health and Human Services (HHS) ,
Employee Retirement Income Security Act (ERISA) ,
Fundraisers ,
HIPAA Omnibus Rule ,
HITECH Act ,
Marketing ,
Notice Requirements ,
OCR ,
PHI ,
Privacy Rule ,
Risk Assessment ,
Subcontractors ,
Training