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
We work closely with employers (mostly ALEs) and an array of service providers – payroll processors, benefit plan consultants and administrators, software developers and transmitters, employee leasing firms, insurance brokers...more
In June 2013, DOL, HHS and IRS explained that they view employer-sponsored wellness programs as narrow exceptions to the ACA’s health status discrimination prohibition. Early this year, the EEOC slathered-on its own rules,...more
11/4/2015
/ Affordable Care Act ,
Americans with Disabilities Act (ADA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Discrimination ,
Employer Group Health Plans ,
Equal Employment Opportunity Commission (EEOC) ,
GINA ,
Inducement ,
IRS ,
Spouses ,
Wellness Programs
In Notice 2015-60 (October 9, 2015), the IRS announced that the PCORI fee will rise to $2.17 per covered life for plan years ending on or after October 1, 2015 and before October 1, 2016. For plan years ending on or after...more
We were asked that recently, proving that there is such a thing as a wrong question. Let’s break it down. The same person may be both a “seasonal worker” and a “seasonal employee,” but those terms are used to discuss separate...more
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
9/22/2015
/ Affordable Care Act ,
Appeals ,
Centers for Medicare & Medicaid Services (CMS) ,
Certifications ,
Department of Health and Human Services (HHS) ,
Employer Mandates ,
Federal Health Insurance Exchanges ,
Guidance Update ,
Health Insurance ,
Health Insurance Exchanges ,
Healthcare.gov ,
IRS ,
Public Health Insurance Marketplace ,
Reporting Requirements ,
Subsidies ,
Tax Credits ,
Tax Liability
On September 16, 2015, the IRS finalized these ACA coverage reporting Forms and Instructions... We report here, with minimal analysis, changes that we recognized on first comparison to the 2015 Draft Forms and Instructions....more
9/21/2015
/ Affordable Care Act ,
COBRA ,
Employer Mandates ,
Health Insurance ,
HRA ,
Insurance Industry ,
IRS ,
Medicare ,
Minimum Essential Coverage ,
Multiemployer Plan ,
Reporting Requirements ,
Required Forms ,
Self-Insured Health Plans ,
TRICARE
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
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
On August 18, 2014, we posted our, “First Look at ACA Employer Compliance Software.” It’s time for an update. We invited less than a dozen vendors to answer these twenty-two questions....more
8/26/2015
/ Affordable Care Act ,
Employee Benefits ,
Form 1094 ,
Form 1095 ,
IRS ,
Large Employer ,
Payroll Taxes ,
Software ,
Surveys ,
Technology ,
Vendors
At about the same time as last year, the IRS has released draft ACA coverage information reporting Forms and Instructions to be used early next year. There are many small differences and one HUGE difference. The IRS decided...more
8/13/2015
/ Affordable Care Act ,
COBRA ,
Employer Group Health Plans ,
Form 1094 ,
Form 1095 ,
Form 8809 ,
Full-Time Employees ,
IRS ,
Multiemployer Plan ,
Required Forms ,
W-2
This seems to be a trend. ACA amendments with some bipartisan support can get done if they are buried in unrelated legislation. When the President signed H.R. 3236, the ACA employer mandate was amended to promote small...more
Code § 4980I (a/k/a/ the “Cadillac Plan tax”) was added by the ACA so that taxpayers with average group health plans would not subsidize, by tax preference, rich plans benefitting chiefly the rich. Section 4980I imposes a...more
Absent applicable transitional relief, most of which vanishes after 2015, an ACA Applicable Large Employer that fails to offer Minimum Essential Coverage to at least 70% of its 2015 full-time employees and their dependents...more
If you had at least 50 but less than 100 full-time employees (on an aggregated basis, including full-time equivalents) in an average month in 2014, then you are an ACA “Applicable Large Employer” with ALE reporting...more
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
6/29/2015
/ Affordable Care Act ,
Annual Assessments ,
Budgets ,
Centers for Medicare & Medicaid Services (CMS) ,
Employer Mandates ,
Full-Time Employees ,
Health Insurance ,
Healthcare.gov ,
IRS ,
State Health Insurance Exchanges ,
Subsidies ,
Tax Assessment