News & Analysis as of

Health Insurance Benefit Plan Sponsors Safe Harbors

Bricker Graydon LLP

Is My Health Plan Affordable Enough?

Bricker Graydon LLP on

As employers increasingly struggle with rising health plan costs, the IRS has provided some good news. Recently, the IRS announced that the Affordable Care Act (ACA) affordability threshold will increase to 9.96% of household...more

Vorys, Sater, Seymour and Pease LLP

Telehealth Services Safe Harbor for High Deductible Health Plans Expires December 31, 2024

On December 21, 2024, President Biden signed into law the American Relief Act, 2025 (2025 Relief Act), which funds the federal government through March 14, 2025, and provides certain disaster relief provisions and other...more

Bricker Graydon LLP

You May be Able to Increase Health Plan Premiums and Stay Affordable in 2025

Bricker Graydon LLP on

For the first time in four years, the IRS adjusted the affordability percentage used for the shared responsibility penalties. The IRS recently announced that the affordability percentage for 2025 will be 9.02%....more

Baker Donelson

ACA Affordability Test Will Be More Difficult to Pass in 2024

Baker Donelson on

As employers are preparing for 2024 open enrollment, they should be aware that the Affordable Care Act (ACA) affordability safe harbors are going DOWN for 2024. The IRS has just released Revenue Procedure 2023-29, which...more

McDermott Will & Schulte

New MHPAEA Guidance Regarding NQTLs: Network Access and Composition

Recently proposed regulations attempt to ensure that health plans allow access to mental health or substance use disorder (MH/SUD) benefits as easily as medical or surgical (M/S) benefits. The proposed regulations, issued by...more

Holland & Knight LLP

IRS Clarifies HDHP Coverage of COVID-19 Testing, Treatment Before Deductible

Holland & Knight LLP on

The IRS recently issued Notice 2023-37 (Notice) relating to pre-deductible coverage of COVID-19 testing and treatment under high-deductible health plans (HDHPs). Specifically, the Notice establishes a 2024 expiration date for...more

Faegre Drinker Biddle & Reath LLP

Navigating Open Enrollment Notice Requirements

Fall open enrollment is upon us, and plan sponsors and administrators are preparing to provide their employees with the required notices related to their health and welfare plans. Notice and disclosure obligations for health...more

Foley & Lardner LLP

Safe Harbors for Offering Health Coverage via an Individual Coverage Health Reimbursement Arrangement

Foley & Lardner LLP on

The Internal Revenue Service (“IRS”) released final regulations... that permit employers to set aside pre-tax funds into health reimbursement arrangements (“HRAs”) that can be used by employees to pay for premiums and other...more

Proskauer - Employee Benefits & Executive...

New HRA Regulations Part 5 – More on the Employer Shared Responsibility Mandate

On September 30th, the IRS issued proposed regulations that establish safe harbors for compliance with the employer mandate in the context of individual coverage health reimbursement arrangements (or “ICHRAs”). These proposed...more

Proskauer Rose LLP

ERISA Newsletter - Third Quarter 2019

Proskauer Rose LLP on

In this edition of our Newsletter, we take a look at a pair of cases that, while unrelated, together remind us of the importance of having clear plan rules in place that reflect the plan sponsor’s intention. The first article...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 3 – Premium Tax Credit and Employer Mandate Impact on Individual Coverage HRAs

As part of our ongoing series on the final regulations expanding the availability of health reimbursement accounts (“HRAs”), we discussed the newly-created Individual Coverage HRAs, which generally allow for employers to...more

Seyfarth Shaw LLP

Different Strokes for Different Folks: The Feasibility of Implementing Different Benefits Plans for Different Categories of...

Seyfarth Shaw LLP on

In the growth of the gig economy, many employers are increasing the number of categories of their employees and associates. One challenge of the gig economy is determining when a worker qualifies as a full-time employee for...more

King & Spalding

November and December 2015 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

King & Spalding on

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...more

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