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HHS 2017 Notice of Benefit and Payment Parameters

This is the annual hodge-podge of changes to the risk adjustment, reinsurance, and risk corridors programs, cost sharing parameters, cost-sharing reductions, and Healthcare.gov user fees, usually filling hundreds of Federal...more

Healthcare.gov: No 2015 Employer Subsidy Notices

On September 18, 2015, the Centers for Medicare and Medicaid Services (CMS) published a set of “Frequently Asked Questions Regarding the Federally-Facilitated Marketplace’s (FFM) 2016 Employer Notice Program.”...more

Outside Counsel Should Handle Healthcare.gov Subsidy Appeals

Here’s the coming dilemma: let IRS assess employer mandate taxes based on errant Healthcare.gov subsidy certifications or appeal those errors to prevent those assessments.  “Where’s the dilemma?” you say.  Here:  once you...more

Top Ten Healthcare.gov Subsidy Counties in Each SEC State

Why should you care? Subsidy certification of even one applicant claiming to be a full-time employee not offered affordable, qualifying 2015 coverage can cause the IRS to assess a non-deductible tax against the applicant’s...more

Budgeting for Employer Mandate Tax Assessments

For October 1 fiscal year employers, it’s budget season. Calendar year employers aren’t far behind. Those doubting their employer mandate compliance need to accrue reserves for non-deductible assessments that the IRS may...more

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