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Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.Blog Contributors
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Finally, Some Good News: IRS Extends Certain ACA Reporting Deadlines and Transition Relief
As in prior years, the IRS has provided relief for employers preparing to comply with the Affordable Care Act’s (“ACA”) information reporting requirements in early 2021 for the 2020 calendar year. In particular, Notice 2020-76 (the “Notice”) extends the deadline … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, deadlines, extension, notice 2020-76, reporting
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IRS Letters 226J: Having the Right Section 4980H Records Can Be Worth a Small Fortune
As reported in our 2018 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare, the Section 4980H penalties are still in effect and the IRS is enforcing them. Employers continue to receive Letters 226J, which the … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, Affordable Care Act, Form 1094-C, Form 1095-c, IRS, letter 226j, recordkeeper, vendor
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Seeing the Big Picture – How Proposed Health Reimbursement Arrangements Might Harmonize with Existing Law
On October 29, 2018, proposed regulations were published in the Federal Register that would permit employers to offer two new types of health reimbursement arrangements (“HRAs”) that align with the requirements of the Affordable Care Act (the “ACA”). The proposed … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 2018-88, 4980H, ACA, HRA, IRS, Notice
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Texas Judge Declares the Affordable Care Act Unconstitutional – What’s Next?
As reported in our “2018 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare,” the Tax Cuts and Jobs Act repealed the individual mandate, which spawned a lawsuit challenging the whole of the Affordable Care Act … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 226J, 4980H, ACA, Affordable Care Act, repeal
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A Holiday Surprise – IRS Extends Certain ACA Reporting Deadlines and Transition Relief
The IRS delivered welcome news to employers preparing to meet the Affordable Care Act’s (“ACA”) information reporting deadlines in early 2019 for the 2018 calendar year. In Notice 2018-94 (the “Notice”), the IRS extended the employer’s deadline to furnish Forms … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, extension, reporting
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Count Down to Open Enrollment – Some Quick Thoughts
As open enrollment approaches for the 2019 calendar year, below are some items employers may want to consider: Wellness program changes – Many employers change their wellness programs during open enrollment. This is a reminder that even small changes to … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged 4980H, association health plans, coverage, domestic partners, open enrollment, premiums, wellness
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The 95 Percent Test: Gearing up for Another Round of Employer Shared Responsibility Penalties
Late last year, the Internal Revenue Service (the “Service”) began enforcing penalties with respect to failures to comply with the employer shared responsibility provisions of Section 4980H of the Internal Revenue Code. In the coming months, the Service is expected … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, ALE, IRS, letter 226j, penalties
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IRS to Begin Enforcing 4980H Penalties on Large Employers Before End of 2017
On November 2, 2017, the IRS issued guidance regarding the enforcement of Employer Shared Responsibility payments, otherwise known as the Section 4980H penalty. Questions 55-58 of the IRS Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, Affordable Care Act, employer shared responsibility, health care reform, health plans, IRS, large employer penalties, minimum essential coverage
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Open Enrollment Looms and ACA Changes are Uncertain – What are Employers to Do?
On the morning of July 28, 2017, another effort to repeal or replace the Affordable Care Act (“ACA”) failed in a 49-51 Senate vote when three Republican senators voted against the bill. Attempts to pass even a trimmed down “skinny” … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 4980H, ACA, enrollment, health care reform, Mental Health Parity, MHPAEA, open enrollment, repeal, SBC, Senate, summary of benefits and coverage, template, wellness
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