Departments Provide Some Relief to Health Plan Sponsors Facing Looming Year-End Deadlines

Year-end is always a scramble for health plan sponsors as they go through renewal and open enrollment.  This year was looking to be worse than normal given the impending deadlines for complying with the transparency in coverage regulations (“TiC”) and … Continue reading

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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

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Congress Giveth and They Taketh Away — Recent Health Plan Changes

In enacting the Further Consolidated Appropriations Act, 2020, (the “Act”), Congress, among other changes, enacted the following key changes affecting employer group health plans: Repeal of the Cadillac Tax:  Most notably, and a huge relief to most employers, Congress repealed … Continue reading

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What is the Fate of ACA? No Answers Yet from the Fifth Circuit.

Background As noted in our previous December 2018 blog post, “Texas Judge Declares the Affordable Care Act Unconstitutional – What’s Next?,” and our October 2019 newsletter, “2019 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare,” … Continue reading

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A Post-Thanksgiving Treat: IRS Extends Certain ACA Reporting Deadlines and Transition Relief

The IRS provided welcome news to employers preparing to comply with the Affordable Care Act’s (“ACA”) information reporting requirements in early 2020 for the 2019 calendar year. In particular, Notice 2019-63 (the “Notice”) extends the deadline to furnish Forms 1095-B … Continue reading

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Preventive Care Can Now Be Covered for Specified Chronic Conditions Before HDHP Deductible

On July 17, 2019 the IRS released Notice 2019-45  resolving a preventive care problem that has been plaguing many high deductible health plans (“HDHPs.”).  The Affordable Care Act’s free preventive care mandate appears to be working.  People are catching medical … Continue reading

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Reassigning Section 1557: Trump Administration Proposes Reversal of Transgender Benefits Rule

In 2016, the Department of Health and Human Services (“HHS”) Office of Civil Rights issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act (“Section 1557”), which prohibit the categorical refusal of health coverage to transgender participants and … Continue reading

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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

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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

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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

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