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Guidance Addresses Mental Health Parity

The U.S. Departments of Labor, Health and Human Services, and the Treasury have issued a set of Frequently Asked Questions and Answers that, among other things, implement certain of the recommendations included in a report...more

IRS Proposes Adjustments in Individual Mandate Reporting

The IRS has issued proposed regulations on the individual mandate reporting requirements under section 6055 of the Internal Revenue Code. To a significant degree, the new regulations reflect guidance previously published by...more

EEOC Finalizes Wellness Program Regulations

The Equal Employment Opportunity Commission has published final regulations and a set of questions and answers on how the Americans with Disabilities Act (ADA) applies to employer-sponsored wellness programs that offer...more

Supreme Court Restricts State Medical Claims Data Reporting Law

ERISA does not allow a state to compel a self-insured group health plan to compile and report medical claims data for inclusion in a state-wide all-payer health care database, the U.S. Supreme Court has ruled in a landmark...more

IRS Issues Second Guidance on Cadillac Tax

The Internal Revenue Service has issued a new notice addressing issues relating to future rules governing the calculation and payment of the so-called “Cadillac tax” under the Affordable Care Act. Beginning in 2018, the ACA...more

EEOC Tackles Wellness Programs

After much silence, some litigation, and recent congressional hearings, the Equal Employment Opportunity Commission (EEOC) has at long last proposed regulations (together with a fact sheet and set of frequently asked...more

Partial Relief for Employer Payment of Individual Insurance Premiums

In a recent notice, the Internal Revenue Service has tempered prior guidance that closed the door on employer arrangements for paying the cost of individual health insurance for employees. The IRS still views these premium...more

Supreme Court Addresses an Employer’s Right To Amend Retiree Health Coverage

In M&G Polymers v. Tackett, the U.S. Supreme Court ruled that ordinary contract principles govern whether a collective bargaining agreement vests retirees in health coverage (and the contributions they are required to pay for...more

Expatriate Plans Exempted from Many Affordable Care Act Provisions

In the Consolidated and Further Continuing Appropriations Act (the recently enacted federal budget bill often known as the “CRomnibus” legislation), Congress has exempted health plans designed to cover expatriates from most...more

Health Plan ID Program Suspended

Late on October 31, the Centers for Medicare and Medicaid Services (CMS) Office of E-Health Standards and Services announced that it was suspending the program that required all health plans to register for a health plan ID...more

Midyear Check on Health Plan Compliance

If you sponsor or administer a group health plan, you are almost certainly taking steps to prepare for legal requirements that will become effective on or before January 1, 2015. New rules under HIPAA, the Affordable Care Act...more

IRS Revises Form for Payment of Fee To Fund Patient-Centered Outcomes Research

The Internal Revenue Service (IRS) has issued an updated version of IRS Form 720 and the instructions. Self-funded group health plan sponsors and health insurers must use this form to report and pay the fee required to fund...more

More Guidance Issued on Summaries of Benefits and Coverage

The U.S. Department of Labor has issued a set of frequently asked questions, together with a new template, for the Summary of Benefits and Coverage (SBC) that applies to group health plans and individual health insurance. The...more

Supreme Court Upholds Health Plan’s Right To Recover Money from Third Party

The U.S. Supreme Court has ruled that the clear terms of an employer's group health plan override an employee's equitable defenses in determining the plan's right to recover amounts from a third party. This decision points...more

Agencies Propose Regulations on the 90-Day Waiting Period Requirement

The U.S. Departments of Health and Human Services, Labor, and Treasury have released a joint set of proposed regulations implementing the requirement in the Patient Protection and Affordable Care Act that group health plans...more

IRS Releases Further Guidance on Employer Health Care Coverage Mandate and Penalties

The Internal Revenue Service has released proposed regulations and FAQs on the shared responsibility provisions of the Affordable Care Act (ACA). These rules require large employers to offer full-time employees and their...more

Government Agencies Provide Guidance on Taxes and Fees under the Affordable Care Act

In regulations and other pronouncements issued toward the end of 2012, the government has provided further details on new taxes and fees introduced by the Affordable Care Act (ACA)....more

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