News & Analysis as of

Reporting Requirements Self-Funded Health Plans

Warner Norcross + Judd

Group Health Plan PCORI Fees Due by July 31 - UPDATED JULY 2025

As a reminder, the deadline for submitting Patient-Centered Outcomes Research Institute (PCORI) fees is July 31. Employers who sponsor self-insured group health plans should report and pay PCORI fees using the most recently...more

Bricker Graydon LLP

Is My Group Health Plan Covered by State PBM Reporting Laws?

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State laws seeking to regulate pharmacy benefit managers (PBMs) have increased significantly over the past few years. As it stands, all 50 states have laws that regulate PBMs in some way, but all are unique. However, most of...more

Venable LLP

July Filing Deadlines for Employee Benefit Plans

Venable LLP on

By July 31, employers that sponsor self-funded medical plans must report and pay their PCORI fee. By July 31, employers that sponsor calendar-year employee benefit plans that are subject to ERISA must file a Form 5500 (unless...more

Bass, Berry & Sims PLC

Stuck in the Middle: Self-Funded Health Plans and Recent Challenges to State PBM Laws

In recent years, prescription drug prices have been top-of-mind for state legislators, who have responded by passing laws that seek to control that pricing in a variety of ways, including by regulating pharmacy benefit...more

Bricker Graydon LLP

What, Me PCORI? - Fee Update for Self-Funded Plans

Bricker Graydon LLP on

While the Patient-Centered Outcomes Research Initiative (“PCORI”) fee was updated at the turn of the year, the fee is not actually paid until July.  For those of you that forgot about the fee, this is your reminder to start...more

Bricker Graydon LLP

Gag Clause Attestations due December 31, 2023

Bricker Graydon LLP on

If you sponsor a group health plan, make sure you set a calendar alert before the winter holidays to submit the annual gag clause prohibition compliance attestation. Under the Consolidated Appropriations Act of 2021 (CAA),...more

McDermott Will & Emery

IRS Issues Final Regulations Extending ACA Information Reporting Deadlines, Clarifies Additional ACA Issues

McDermott Will & Emery on

On December 15, 2022, the Internal Revenue Service (IRS) finalized regulations regarding Information Reporting of Health Insurance Coverage and Other Issues Under Internal Revenue Code (Code) Sections 5000A, 6055 and 6056...more

Perkins Coie

Contractual Considerations for Self-Funded Group Health Plan Sponsors in 2022

Perkins Coie on

In our January 2022 update, we discussed new federal requirements that group health plans should pay close attention to in 2022. The sponsor of a self-funded plan will need to work closely with its legal counsel, benefits...more

Winstead PC

Good News on Health Coverage Reporting for 2018 Coverage

Winstead PC on

Normally, the deadline for reporting health care coverage by a self-insured medical plan or an insured plan follow rapidly after year end. In an early holiday gift, the Internal Revenue Service (the “Service”) provided an...more

Foley & Lardner LLP

Thank You IRS - Extensions for This Year’s ACA Tax Reporting

Foley & Lardner LLP on

The “Bottom Line” - Employers will have until March 2, 2018 to furnish Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”) to employees.,,...more

BCLP

IRS Addresses ACA Reporting Requirements Self-Funded Plans, HRAs

BCLP on

As promised in Notice 2015-68, the IRS has proposed clarifications to the regulations under IRC Section 6055 relating to information reporting rules for minimal essential coverage providers. These rules affect employers...more

Seyfarth Shaw LLP

Supreme Court Concludes That ERISA Preempts State Reporting Requirements

Seyfarth Shaw LLP on

In a closely observed federalism battle over the scope of ERISA preemption, the Supreme Court came down on the side of Federal power. Specifically, in Gobeille v. Liberty Mutual Insurance Company, the Court, in a 6-2 ruling,...more

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

ERISA Preemption Made Easy? Supreme Court Sends Vermont All-Payer Database Back to the Drawing Board

On the first day of decisions since the unexpected passing of Justice Scalia, the Supreme Court of the United States ventured into the thorny area of preemption under the Employee Retirement Income Security Act (ERISA) and...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

Snell & Wilmer

New Draft Instructions Released for ACA Information Reporting

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As explained in my previous blog, Code Sections 6055 and 6056, added by the Affordable Care Act (“ACA”), require all employers (even small employers) sponsoring self-funded health plans and large employers to file information...more

Snell & Wilmer

ACA Information Reporting Penalties Have Been Increased

Snell & Wilmer on

Code Sections 6055 and 6056 require large employers and all employers (even small employers) sponsoring self-funded health plans to file information returns with the IRS and furnish statements to applicable employees...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 2 of 24): Yikes! The Costs of Failing to Comply...

The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...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

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