Both reporting requirements have a delayed effective date of January 1, 2015 (originally effective January 1, 2014) with initial reporting and disclosure in 2016. In September, 2013, the IRS issued proposed regulations regarding ALE reporting as well as MEC reporting which modify the statutory language but leave the door open for increased reporting requirements. Refer […]
ACA, Disclosure, ReportingIn our last ErisaALERT we covered the basics of the shared responsibility requirements and provided highlights of the proposed regulations. In this ErisaALERT we will dig a little deeper into some aspects of the proposed guidance. At the end of the document is a glossary of some key terms. The proposed regulations are complex; there […]
ACA, shared responsibilityOn January 2, 2013 the IRS issued proposed regulations regarding Shared Responsibility Regarding Health Coverage. The proposed regulations offer some clarification, flexibility and transition rules. The material is complex and will be discussed in three ErisaALERTs. In this ErisaALERT, we will summarize key provisions of both the statute and the proposed regulations. In Part II […]
ACA, shared responsibilityErisaALERT© The IRS recently issued Notices 2012-58 and 2012-59. Notice 2012-58 addresses the determination of full-time employee status for purposes of shared responsibility. Notice 2012-59 addresses the 90 day waiting period requirements. This Alert summarizes important points in each notice and provides a to-do list for plan sponsors. Notice 2012-58 will be of particular interest […]
2012 archive, 90 day waiting period, ACA, DOL Technical Release, ERISA, Notice 2012-58, Notice 2012-59ErisaALERT 2011-16 described the guidance regarding Medical Loss Ratio (MLR) rebates. Since that ALERT was issued the IRS has issued guidance FAQs regarding the tax treatment of the MLR rebates. Many plan sponsors have recently received letters from their insurance companies indicating that a check will be in the mail. Insurance companies have sent letters […]
2012 archive, ACA, minimum loss ratio, MLRThe Affordable Care Act imposes fees on issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans. The fees are generally referred to as the comparative effectiveness research fees. The IRS recently issued proposed regulations regarding the fee. This ALERT will focus on employer sponsored group health plans. Bottom Line: The […]
2012 archive, ACA, CER, comparative effectiveness research fee, PCORIOn March 19, 2012 the IRS, DOL and HHS jointly issued Frequently Asked Questions (FAQs) Affordable Care Act Implementation (Part VIII) regarding the implementation of the Summary of Benefits and Coverage (SBC) requirements under the Affordable Care Act Implementation (Part VIII of the Act). We provided an extensive description of the proposed SBC regulation in […]
2012 archive, ACA, SBCThe IRS, DOL and HHS jointly published final regulations regarding the Summary of Benefits and Coverage and Uniform Glossary as well as other guidance regarding the SBC in February. The regulations indicate that this guidance is for the first year of applicability and the Departments intend to issue updated material for later years. You can […]
2012 archive, ACA, SBCForm W-2 Reporting The Affordable Care Act required informational reporting of the aggregate cost of employer sponsored group health plan coverage beginning with 2012 W-2s issued in January 2013 (ErisaALERT 2011-5 and ErisaALERT 2011-14). The IRS provides new guidance in Notice 2012-9 which restates and supersedes previous guidance. In this latest Notice, the IRS clarifies […]
2012 archive, ACA, w-2 reporting(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business