Final regulations under Code § 4980H published in the Federal Register on February 12 include a new term—“limited non-assessment period”—which describes periods for which an applicable large employer (i.e., an employer with...more
The last few weeks have produced a regulatory frenzy under various provisions of the Affordable Care Act affecting employers...more
On March 5th, 2014, the Treasury Department and the IRS issued two final reporting rules of critical importance to employers...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
So much attention has been paid to the issuance of the final employer shared responsibility regulations that some might have missed the news that final regulations were recently issued under another of the Affordable Care...more
The Treasury Department and Internal Revenue Service recently issued final regulations implementing the employer shared responsibility provisions of the Affordable Care Act. For “applicable large employers” — i.e., those with...more
In last week’s post on the topic of the recently issued final regulations under the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules, we suggested that the final regulations broke little new...more
The Treasury Department and the IRS last week issued long-awaited final rules implementing the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules. Originally slated to take effect beginning...more
A January 18th New York Times article (Rules for Equal Coverage by Employers Remain Elusive Under Health Law) reported on the progress, or lack thereof, of the adoption of group health plan non-discrimination regulations...more
Breaking with long standing tradition—i.e., issuing important rules on a Friday before a holiday weekend, or (failing that) any Friday (hence the reference to Week 45½ in this post)—the Treasury Department and the IRS today...more
The Affordable Care Act establishes three new, high-level, reporting requirements:
Code § 6051(a)(14) -
Employers must report the cost of coverage under an employer-sponsored group health plan on an employee’s...more
A handful of recent guidance items that the Departments of Labor, Health and Human Services, and Treasury have issued make some important changes related to the regulation of “excepted benefits.” These changes are driven in...more
A recent Federal Court decision turned back a potentially debilitating challenge to the Affordable Care Act’s rules governing premium subsidies. The decision, Halbig v. Sebelius, has consequences for large employers, i.e.,...more
So where are they?
Final regulations implementing the Affordable Care Act’s rules governing shared responsibility of employers were widely expected to have “dropped” before the beginning, or perhaps during the first...more
The Affordable Care Act imposes a series of interrelated requirements on individuals, employers and providers. Individuals must maintain coverage or face the prospect of a tax penalty; carriers must offer and renew coverage....more
(Note: This is the first installment of a series of entries that Alden will be posting each week for the next 51 weeks as he counts down to the January 1st, 2015 ACA pay-or-play deadline).
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The Obama administration's July 2013 announcement, delaying enforcement of the employer mandate under the Affordable Care Act by one year, has affected not only when employees must be offered health insurance coverage but...more
On November 13, 2013, the Departments of the Treasury, Labor and Health and Human Services (the “Departments”) issued final regulations under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act...more
In addition to imposing substantive requirements on health insurance issuers in the group and individual markets and employer-sponsored group health plans, the Patient Protection and Affordable Care Act (Act) imposes three...more
On September 13, 2013, the Department of Labor and the Treasury Department/IRS (the “Departments”) issued coordinated guidance on a handful of items relating to the implementation of the Affordable Care Act (the “Act”),...more
The Patient Protection and Affordable Care Act (the “Act”) amends the Fair Labor Standards Act (“FLSA”) to require employers of all sizes to provide their employees a notice of the availability of coverage through public...more
8/21/2013
/ Affordable Care Act ,
COBRA ,
Compliance ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Mandates ,
Fair Labor Standards Act (FLSA) ,
Health Insurance Exchanges ,
Healthcare ,
Marketplace Notice ,
Notice Requirements
Established as a part of the comprehensive 2006 Massachusetts health care reform law, the Massachusetts Health Insurance Connector (a/k/a the “Connector”) served as a model for the American Health Benefit Exchanges that are a...more
On July 9, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....more
In a move that took many by surprise, the Obama Administration on July 3 announced a one-year delay (to January 1, 2015 from January 1, 2014) in the enforcement of the employer mandate under the Patient Protection and...more
In a surprise announcement posted Tuesday to the White’s House website, the Obama Administration announced a one-year delay (to January 1, 2105) in the enforcement of the employer shared responsibility rules enacted into law...more