Individuals enrolled in or eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage have a new special enrollment period to sign up for qualified health plan (QHP) coverage through the marketplace. Last month, the Department of Labor (DOL) released a new model COBRA notice. The new notice makes it clear that individuals may have […]
ACA, COBRAErisaALERT 2013-05 discussed the statutory requirements and the proposed regulations regarding the new reporting and disclosure requirements imposed by the Affordable Care Act (ACA) relating to the individual mandate and shared responsibility. On March 10, 2014 final regulations were issued for §6055 Information Reporting of Minimal Essential Coverage (MEC) and §6056 Information Reporting by Applicable […]
6055, 6056, ACA, Disclosure, ReportingWe previously covered the shared responsibility requirements in ErisaALERT 2012-13, 2013-01 and 2013-02. Many of the provisions in the proposed rule carry over to the final regulations. The regulations continue to be very complex and will require careful review as it relates to your particular situation. In this ALERT we will discuss some of the […]
ACA, shared responsibilityOn November 8, 2013, the Departments of Labor, Health and Human Services, and the Treasury (the Departments) issued final rules on the Mental Health Parity Addiction Equity Act of 2008 (MHPAEA). Concurrently, the Departments posted Frequently Asked Questions related to the final rule. There is also a question relating to MHPAEA in the latest Frequently […]
ACA, Affordable Care Act, Mental health parity, MHPAEA, WellstoneBoth 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, ReportingPlan sponsors intending to use the Form 5500 method for counting covered lives for the PCORI fee, take note! If you have a self-insured health plan subject to the PCORI fee with a calendar year plan year and intend to use the Form 5500 method to count covered lives, you cannot utilize the 2 ½ […]
ACA, Form 5500In 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, MLR(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business