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 disclosureImpact 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” […]
ACAOn 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, SBCThis 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 disclosureIRS 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 responsibilityThis ALERT will provide a high level overview of what looks likely to be a very complicated process if the Notices are any indication. Background The Cadillac tax under the Affordable Care Act applies to taxable years beginning after December 31, 2017. It imposes a 40 per cent nondeductible excise tax on employer-sponsored health coverage […]
ACA, Cadillac, Cadillac tax, excise taxErisaALERT 2014-11 – What is the transitional reinsurance fee? The Affordable Care Act established a three-year (2014, 2015 and 2016) transitional reinsurance program to stabilize premiums in the individual market inside and outside of the Marketplaces. Who must pay the transitional reinsurance fee? A contributing entity must make reinsurance contributions on behalf of its enrollees […]
ACA, compliance, HCR, transitional reinsurance feeErisaALERT 2014-10 – What is an HPID? Note: Late on October 31, HHS announced a delay HPID requirement. A health plan identifier (HPID) is intended to increase standardization within HIPAA standard transactions. Both the Affordable Care Act and the Social Security Act require the adoption of a standard unique health plan identifier. Covered entities are […]
ACA, Affordable Care Act, HCR, Health Plan Identifier, HPIDErisaALERT 2014-09 – ACA’s shared responsibility provisions impose penalties on individuals who do not maintain minimum essential coverage (MEC) and on plan sponsors who do not offer minimum value, affordable coverage. The way the IRS will know if an individual has MEC and if an employer offers minimum value, affordable coverage is via the §6055 […]
6055, 6056, ACA, compliance, Disclosure, HCR, ReportingThe DOL, IRS and HHS have issued final regulations clarifying the maximum length of an employee orientation period in light of the 90-day waiting period limitation ErisaALERT 2012-13 under the Affordable Care Act (ACA). To guard against potential subterfuges for the passage of time, final regulations provide that one month is the maximum allowed length of […]
90 day waiting period, ACA, orientation period(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business