Massachusetts Paid Family and Medical Leave, M.G.L c. 175M (“MAPFML”) establishes a system of paid leave of up to 12 weeks for birth, adoption or foster care, 12 weeks to care for a family member, 20 weeks for an employee’s...more
9/18/2019
/ Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Contributions ,
Employer Liability Issues ,
Exemptions ,
Form 5500 ,
Medical Leave ,
Paid Family Leave Law ,
Paid Leave ,
Preemption ,
State Labor Laws ,
Wage and Hour
Responding to widespread resistance—principally on the part of small businesses—to the increase in the Employer Medical Assistance Contribution (“EMAC”) contributions and the addition of an EMAC supplemental contribution,...more
Adherence to the COBRA health care continuation rules is not always high on an employer’s list of priorities. Compliance is often “outsourced,” and even when handled “in-house,” it rarely consumes much attention. A recent...more
In a series of blog posts going back to last August, we reported on certain amendments to the Massachusetts Employer Medical Assistance Contribution (EMAC) rules. As we previously explained, the EMAC contributions are...more
The Massachusetts Department of Unemployment Assistance (DUA) has begun assessing Employer Medical Assistance Contribution (EMAC) supplemental payments for the first quarter. This post proposes a grounds for appealing DUA...more
On January 3, 2018, the Department of Labor issued proposed regulations that will make it easier for small employers to band together to form “association health plans” (“AHPs”), thereby providing access to more liberal...more
1/11/2018
/ Affordable Care Act ,
Association Health Plans ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employer Liability Issues ,
Executive Orders ,
Health Insurance ,
MEWAs ,
Proposed Regulation ,
Trump Administration
Mull v. Motion Picture Ind. Health Plan educates employers on the basics of the requirements of the Employee Retirement Income Security Act (ERISA) governing plan documents and summary plan descriptions. The lessons are...more
8/22/2017
/ Appeals ,
Benefit Plan Sponsors ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employer Liability Issues ,
Motion Picture Industry ,
Plan Administrators ,
Plan Documents ,
Subrogation ,
Summary Plan Description
As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more
10/29/2015
/ Affordable Care Act ,
American Bar Association (ABA) ,
COBRA ,
Employer Group Health Plans ,
Employer Liability Issues ,
Final Rules ,
Form 1094 ,
Form 1095 ,
Full-Time Employees ,
Health Insurance ,
IRS ,
Part-Time Employees ,
Reporting Requirements ,
Safe Harbors ,
Self-Funded Health Plans ,
Shared Responsibility Rule ,
Termination ,
U.S. Treasury
This series is devoted principally to the reporting requirements imposed by Internal Revenue Code §§ 6055 and 6056 as added by §§ 1502 and 1514 of the Affordable Care Act (ACA), respectively. The former reports offers of...more
In Notice 2014-69, the Treasury Department and the IRS clarified that a group health plan that fails to provide substantial coverage for in-patient hospitalization and physician services will not be treated as providing...more
9/30/2015
/ Affordable Care Act ,
Amended Regulation ,
Department of Health and Human Services (HHS) ,
Employer Group Health Plans ,
Employer Liability Issues ,
Health Insurance ,
Hospitals ,
IRS ,
Minimum Essential Coverage ,
Minimum Value Plans ,
Physicians ,
Proposed Regulation ,
Tax Credits ,
U.S. Treasury
The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more
9/22/2015
/ Affordable Care Act ,
COBRA ,
Employer Group Health Plans ,
Employer Liability Issues ,
Expatriates ,
Final Guidance ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HRA ,
IRS ,
Minimum Essential Coverage ,
Minimum Value Plans ,
Multiemployer Plan ,
Proposed Regulation ,
Reporting Requirements ,
Self-Funded Health Plans ,
U.S. Treasury
The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...more
7/27/2015
/ Affordable Care Act ,
Employer Group Health Plans ,
Employer Liability Issues ,
Employer Mandates ,
Good Faith ,
Health Insurance ,
Healthcare ,
IRS ,
Minimum Essential Coverage ,
New Legislation ,
Penalties ,
Reporting Requirements ,
Section 6722 ,
Self-Funded Health Plans ,
Trade Preferences Extension Act (TPEA)
Alden Bianchi, Chair of the our Employee Benefits & Executive Compensation Practice, will provide a weekly installment on the complex reporting obligations outlined by the Affordable Care Act for health insurance carriers and...more
7/20/2015
/ Affordable Care Act ,
Compliance ,
Corporate Counsel ,
Employer Group Health Plans ,
Employer Liability Issues ,
Employer Mandates ,
Exceptions ,
Good Faith ,
Health Insurance ,
Individual Mandate ,
IRS ,
Minimum Essential Coverage ,
Penalties ,
Popular ,
Reporting Requirements ,
Self-Funded Health Plans
Employers and their HR departments are faced with a host of new issues and challenges. When you’re not navigating new state, federal, and local laws and making sure systems are in place to comply with them, you’re busy...more
Regulations implementing the Affordable Care Act’s (ACA) employer shared responsibility rules including the substantive “pay-or-play” rules and the accompanying reporting rules were adopted in February. Regulations...more
While my entries have focused principally on the employer shared responsibility rules of the Affordable Care Act (ACA), every once in a while an item comes along that nevertheless grabs my attention. The treatment of wellness...more
The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...more
For applicable large employers (i.e., employers who employed at least 50 full-time and full-time equivalent employees on business days during the preceding calendar year) endeavoring to comply with the Affordable Care Act’s...more
7/21/2014
/ Affordable Care Act ,
Employer Group Health Plans ,
Employer Liability Issues ,
Employer Mandates ,
Final Rules ,
Full-Time Employees ,
Health Insurance ,
Look-Back Measurement Period ,
Part-Time Employees ,
Seasonal Employment ,
Variable Hour Employees
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