The IRS issued Notice 2020-76 which once again extends the due date for certain information returns under IRC6055 and 6066. A brief recap of the filing requirements: Due date Extended due date Forms 1095-C and 1095-B Statements to Individuals February 1, 2021 March 2, 2021 Submission to the IRS February 28, 2021(paper)March 31, 2021 (iffiled […]
ACA
ErisaALERT CARES Act(Coronavirus, Aid, Relief and Economic Security Act)
The CARES Act was signed into law on March 27, 2020. Some guidance has been issued but more guidance isneeded in many areas, so we are keeping this ALERT simple. The provisions are effective immediately. Someprovisions are of limited duration. It remains to be seen if the restrictions will change. Provision Change Act Section Effective […]
401(k), Cafeteria Plan, DOL, IRSErisaALERT Secure Act(Setting Every Community Up for Retirement Enhancement Act)
Further Consolidated Appropriations Act, 2020 was enacted on December 20, 2019. It is comprised of various “Divisions”. Division N is Health and Human Services Extenders which includes repealing certain ACA provisions and Division O is Setting up Every Community Up for Retirement Enhancement (SECURE) which impacts retirement plans. This ALERT will briefly summarize items of […]
ACA, Affordable Care Act, IRSErisaALERT Transition Relief for Health Coverage Reporting under IRC §6055 and §6056
The IRS issued Notice 2019-63 which once again extends the due date for certain information returns under IRC 6055 and 6066. A brief recap of the filing requirements: Due date Extended due date Forms 1095-C and 1095-B Statements to individual January 31, 2020 March 2, 2020 Submission to the IRS February 28, 2020 (paper) March […]
ACA, Disclosure, ReportingACA reporting and disclosure deadlines extended
The Affordable Care Act added IRC sections §6055 and §6056 which requires insurers, applicable large employers and self-insured plans to provide annual health information returns to the IRS and statements to employees. (See ErisaALERTs 2014-04 and 2014-09 for background information.) The regulations require that the employee statements be provided by January 31 and reported to […]
6055, 6056, ACA, compliance, reporting and disclosureACA Section 1557 What is it all about?
A client recently asked us if a plan sponsor could limit or exclude benefits related to gender transition and our answer – it can be complicated and may be unsettled; check with counsel before making any decisions. BACKGROUND Section 1557 of the Affordable Care Act prohibits discrimination in certain “health programs and activities” on the […]
ACA, ACA 1557, Affordable Care Act, transgenderACA – Don’t let your guard down
Impact of Executive Order on Plan Sponsors – not much at the present time On January 20, 2017, President Trump signed an Executive Order – MINIMIZING THE ECONOMIC BURDEN OF THE PATIENT PROTECTION AND AFFORDABLE CARE ACT PENDING REPEAL. As you read through the Executive Order, the words “to the maximum extent permitted by law” […]
ACAProposed changes to Summary of Benefits and Coverage – 2016
On March 11, 2016, the Department of Labor released FAQs about Affordable Care Act Implementation (Part 30) that addresses implementation dates for the proposed Summary of Benefits and Coverage template and associated documents (published on February 26, 2016). (See ErisaALERT 2012-06 for background information). The government intends to act “expeditiously” to finalize the new documents. […]
ACA, HCA, SBCThe Final Countdown to ACA Reporting and Disclosure Roundup of Useful IRS Resources
This is a roundup of information available on the IRS website. The links are working as of the date of this newsletter! Health Coverage Information Return Deadlines https://www.irs.gov/Affordable-Care-Act/Employers/Mark-Your-Calendars-Health-Coverage-Information-Return-Deadlines Action Reporting Due Dates in 2016 for… Applicable Large Employers – Including Those That Are Self-Insured Self-insured Employers That Are Not Applicable Large Employers Coverage Providers – […]
1095-C, ACA, Affordable Care Act, reporting and disclosureThe Impact of Employer HRA Contributions and Flex-Credits on ACA Affordability Calculations
IRS Notice 2015-87 (“the Notice”) provided guidance in the form of questions and answers on certain group health plan provisions of the Affordable Care Act (ACA). ErisaALERT 2016-01 discussed the impact of opt-out incentives on ACA affordability. This ALERT discusses the impact of employer HRA contributions and flex credits on ACA affordability. Quick overview of […]
ACA, Affordability, flex credits, HRA, shared responsibility