On February 8, 2015, the IRS released final forms and instructions for reporting health coverage pursuant to Code Sections 6055 and 6056, which were added by the Health Care Reform Act. Please see our SW Benefits Update, “Final IRS Forms and Instructions for Reporting Health Coverage Clarify Large Employer Requirements for 2015 and Beyond” for […]
NW
As part of Health Care Reform, employers and insurers are required to provide group health plan participants with a Summary of Benefits and Coverage (“SBC”) describing the important features of the group health plan option(s) offered by the employer/insurer. The SBC is also intended to provide participants a way to easily compare different group health […]
KH
2015 is a significant year for health care reform because the large employer shared responsibility penalties under Internal Revenue Code Section 4980H take effect for most large employers. See our SW Benefits Update, “Health Care Reform’s Employer Shared Responsibility Penalties: A Checklist for Employers,” for a detailed explanation of the large employer penalties. Many people are under […]
NC
Starting in 2016, Section 6055 of the Internal Revenue Code (the “Code”), which was added by the Health Care Reform Act, requires all entities providing “minimum essential coverage” (“MEC”) to submit information to the IRS concerning each covered individual for the 2015 calendar year. Section 6055 also requires these entities to provide statements containing similar […]
NW
The Health Care Reform Act created the transitional reinsurance program, which requires most self-insured health plans to make contributions to HHS for the 2014, 2015, and 2016 calendar years. The contribution amount is determined by the number of covered lives under each plan. The number of covered lives must be calculated and submitted to HHS […]
NW
As explained in my Checklist for Employers, a large employer will have to pay a subsection (a) penalty for any month if it does not offer “minimum essential coverage” (“MEC”) to substantially all (i.e., 70% for 2015 and 95% for future years) of its full-time employees and their dependents if one or more full-time employees […]
NC
Most employee benefit plans are subject to nondiscrimination rules. In order to prevent employers from breaking apart companies in order to avoid these nondiscrimination rules, most employee benefit plans, in performing nondiscrimination testing, must take into account related businesses (i.e., controlled groups and affiliated service groups). I’ve been blogging recently about the large employer shared […]
NC
Last fall the IRS and DOL issued nearly identical guidance, IRS Notice 2013-54 and DOL Technical Release 2013-03, explaining how certain Health Care Reform Act rules apply to health reimbursement arrangements (“HRAs”). Notice 2013-54 is not good news for most HRAs, also called medical expense reimbursement plans (“MERPs”). Executive physical plans are often structured as […]
NC
Health care reform is confusing. There are so many new terms and concepts. One concept that has been getting a lot of attention lately is MEC. MEC stands for “minimum essential coverage” and is a fancy name for basic health coverage. MEC is important for two main reasons — First, starting in 2014, individuals who don’t […]
NC
The proposed regulations included many helpful transition rules. Although I hoped that the transition rules would be extended, I really didn’t think they would be. The good news is — I thought wrong. A package of limited transition rules that applied to 2014 under the proposed regulations has been extended to 2015, including: Special 6 […]
NC
