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Transitioning to Coverage: Three Things to Know About the New Transgender Healthcare Regulations

On May 18, 2016, the Department of Health and Human Services (“HHS”) issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act. As we discussed in our March 30, 2016 blog, the rule prohibits discrimination on the basis of sex and gender identity in the provision of health programs.  In application, the final […]

Late Or Incorrect Forms 1095-C: The IRS Provides Relief, But Only For Employers Acting In Good Faith To Comply Or Who Missed The Deadline Due To Reasonable Cause

Many employers struggled to furnish correct Forms 1095-C to employees by the March 31, 2016 deadline.  Section 6721(a)(2) of the Internal Revenue Code provides penalties for failure to furnish Forms 1095-C to individuals by the deadline.  Although the presumptive penalty is $250 for each delinquent or incorrect return, the penalty amount may be reduced if […]

NC

“A Trap for the Unwary” – Does Your Self-Funded Health Plan Provide Transgender Benefits? It Might Need to Soon.

Assistant Secretary of Labor Phyllis Borzi recently offered informal guidance on the broad scope of nondiscrimination regulations proposed under Section 1557 of the Affordable Care Act. During her remarks at the ABA Labor Section Employee Benefits Committee Meeting in February, Ms. Borzi indicated that the proposed regulations would apply to any health plan that receives […]

IRS Delivers Belated Christmas Gift – Extends ACA Reporting Deadlines

The IRS delivered a late Christmas gift December 28, 2015 when, in Notice 2016-4, it extended the Affordable Care Act (“ACA”) reporting deadlines.  The new deadlines affect distribution and filing of Forms 1094 and 1095 for calendar year 2015 and are provided below. Section 6055 Health Coverage Reporting Old Filing Deadline New Filing Deadline Form […]

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Final Forms and Instructions for ACA Information Reporting Released

The IRS recently released the final forms and instructions for information reporting under the Affordable Care Act (“ACA”).  The final forms and instructions will be used for reporting in 2016 concerning 2015 coverage.  The final forms and instructions can be accessed below. Form 1094-B Form 1095-B Instructions for Forms 1094-B and 1095-B Form 1094-C Form […]

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NW
Former Associate

New Draft Instructions Released for ACA Information Reporting

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 returns with the IRS and furnish statements to employees concerning the health coverage offered or provided to these employees and their […]

NW
Former Associate

ACA Information Reporting Penalties Have Been Increased

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 concerning the health coverage offered or provided to these employees and their dependents.  This information reporting begins in 2016 with respect to 2015 coverage.  […]

NW
Former Associate

King v. Burwell – Supreme Court Confirms Tax Subsidies are Available in All States

In an earlier blog post this year, I discussed the King v. Burwell case and the possible ramifications if the United States Supreme Court did not uphold the Internal Revenue Service position that residents in states with either a state or federal Health Care Exchange are entitled to receive subsidies from the federal government to […]

NC

May Companies Reduce Employee Hours to Avoid ACA Requirements?

The Affordable Care Act (the “ACA”) generally requires that large employers offer health coverage that meets certain requirements to their full-time employees (i.e., employees working 30 hours or more per week) and their children to avoid paying potential tax penalties.  Some employers have decided to reduce certain employees’ hours to less than 30 hours per […]

NW
Former Associate

IRS Issues More Guidance On Employers That Pay For Individual Health Insurance Policies for Employees – Gives Limited Relief to Small Employers

I have blogged more on the topic of how the Health Care Reform Act applies to employers that reimburse employers for individual health insurance policies than any other topic in the last year.  At one point in time, as indicated in my post of June 11, 2014, The IRS Meant What It Said in Notice […]

NC