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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 […]

| 1 min read | Tagged: , , , ,
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

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

EEOC Proposed Regulations May Require Revisions to Your Tobacco Prevention Wellness Program

In our April 21 blog, Wellness Programs: Agencies Issue Helpful Guidance but Look Before You Leap, Nancy Campbell wrote about the release of the much-anticipated EEOC proposed regulations concerning wellness programs.  In her blog, Nancy briefly touched upon some of the differences between the EEOC proposed regulations and the final HIPAA wellness regulations issued by […]

| 3 min read | Tagged: , , ,
NW
Former Associate

IRS Forms and Instructions Finalized for Reporting Health Coverage

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
Former Associate

EAPs That Meet Four Requirements May Avoid Application of Health Care Reform

Benefits provided through an employee assistance program (“EAP”) may be considered group health plan coverage, which would subject the EAP to the health care reform requirements mandated by HIPAA and the Health Care Reform Act, unless the EAP meets the criteria for being “excepted benefits.” In September 2013, the IRS, HHS, and DOL collectively issued […]

NW
Former Associate

HHS Extends November 17 Deadline to Submit Covered Lives Data under Reinsurance Program

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, in an attempt to stabilize premiums in the individual market.  The contribution amount is determined by the number of covered lives under each plan.  For 2014, […]

NW
Former Associate

November 5 Deadline to Obtain HPID Delayed by HHS

On October 31, 2014, HHS announced a delay, “until further notice,” in the enforcement of the regulations pertaining to Health Plan Identifiers (HPIDs) and their use in HIPAA standard electronic transactions.  For more information on the HPID requirements, please see our October 1, 2014 SW Benefits Update, “HIPAA Requires Many Health Plans to Obtain a […]

| 2 min read | Tagged: , ,
MS
Former Partner
NW
Former Associate

Gear Up for Reporting of Health Coverage

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
Former Associate