News & Analysis as of

Internal Revenue Service Health Insurance Corporate Counsel

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Pullman & Comley - Labor, Employment and...

Federal Court Decision Reshapes ACA Enforcement by HHS and IRS

The recent federal district court decision in Faulk Company, Inc. v. Xavier Becerra, et al., No. 24-cv-00609-P (N.D. Tex. 2025) significantly alters the primary mechanism used by the U.S. Department of Health and Human...more

Amundsen Davis LLC

Court Ruling Hamstrings IRS Enforcement of ACA Employer Mandate

Amundsen Davis LLC on

On April 10, 2025, a federal court in Texas issued an opinion in the case of Faulk Co. v. Becerra that significantly impacts how the Affordable Care Act’s (ACA) employer mandate can be enforced. The ruling effectively...more

Woodruff Sawyer

New ACA-Related Laws Provide More Flexibility to Employers

Woodruff Sawyer on

On Monday, December 23, 2024, President Biden signed into law two bills, H.R. 3797 (the “Paperwork Reduction Act”) and H.R. 3801 (the “Employer Reporting Improvement Act”), which will positively impact applicable large...more

Ballard Spahr LLP

Whiplash: The Orderly and Disorderly End to the COVID-19 Declarations

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Summary - Sponsors of employee benefit plans face heightened plan design and administrative challenges in the wake of President Biden’s surprise termination of the COVID-19 national emergency. This unexpected development,...more

Fisher Phillips

5 Most Important Steps for Employers Doing Their 2023 ACA Compliance Planning

Fisher Phillips on

Applicable large employers must adhere to many Affordable Care Act (ACA) rules to remain compliant regarding group health plan offerings. We offer the following checklist of the five most helpful reminders you should take...more

Bradley Arant Boult Cummings LLP

IRS Proposes Regulations on ACA Reporting: Good News and Bad News for Employers

The Internal Revenue Service (IRS) has published proposed regulations that, if finalized, will ease some of the requirements imposed on employers reporting offers of minimum essential health coverage, including a permanent...more

Proskauer - Employee Benefits & Executive...

COBRA Election and Payment Periods: Does One Year of “Tolling” Really Mean One Year?

Remember the DOL/Treasury relief that tolled the COBRA election and payment deadlines for up to one year due to the COVID-19 pandemic (referred to below as “Tolling Relief”)? If you have been wondering whether, under that...more

Proskauer - Employee Benefits & Executive...

An Additional Word from IRS Regarding the ARP COBRA Subsidy

The IRS just released some new supplemental guidance on the COBRA premium subsidy in the American Rescue Plan Act (“ARP”). IRS Notice 2021-46, released July 26, 2021 provides additional color on a handful of discrete subsidy...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

COBRA Subsidy: What We Know Now After Initial DOL Guidance

Less than a month after the American Rescue Plan Act of 2021 (ARPA) was signed into law, new U.S. Department of Labor (DOL) guidance and model forms are clearing up a number of employer concerns about the 100 percent COBRA...more

Proskauer - Employee Benefits & Executive...

IRS Extends ACA Reporting Deadline and Issues Transition Relief

The IRS has not yet finalized the ACA reporting forms (i.e., the 1094-B/C and 1095-B/C) for the 2019 tax year, so it is no surprise that the IRS issued guidance this week extending the deadline to furnish the forms to...more

Franczek P.C.

Recent Developments in Affordable Care Act Compliance: Employer Obligations for 2018 and Beyond

Franczek P.C. on

Over the past year, there has been a significant focus in the press on various attempts to overhaul or repeal key elements of the Affordable Care Act (“ACA”), which was originally passed into law almost eight years ago. While...more

Carlton Fields

A Game Plan for Employers Facing Possible ACA Penalties

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All employers are at risk of receiving a notice from the IRS that they are liable for a penalty under the Affordable Care Act for failing to offer enough employees insurance coverage, or for failing to offer particular...more

Holland & Knight LLP

Affordable Care Act: Understanding Employer Notices From the Marketplaces

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The Affordable Care Act (ACA) established Health Insurance Marketplaces (also called Exchanges) where individuals can shop and enroll in health coverage. Individuals who meet certain criteria are eligible for premium...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 1 of 24)

Alden Bianchi, Chair of the our Employee Benefits & Executive Compensation Practice, will provide a weekly installment on the complex reporting obligations outlined by the Affordable Care Act for health insurance carriers and...more

Ballard Spahr LLP

Partial Relief for Employer Payment of Individual Insurance Premiums

Ballard Spahr LLP on

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

FordHarrison

Affordable Care Act Update: Hospitalization Services Required for Plan to Meet Minimum Value

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On November 4, 2014, the Internal Revenue Service (IRS) released guidance (Notice 2014-69) clarifying that certain group health plans that do not provide for hospitalization services or physician services or both will fail to...more

Poyner Spruill LLP

Still Reimbursing Employees For Health Insurance Premiums? You May Be Subject To Significant Penalties!

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Until very recently, it was not uncommon for employers to reimburse employees for substantiated premiums paid for individual health insurance coverage. Many small employers saw this as a viable alternative to group...more

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