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About this Blog
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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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 1557, ACA, Affordable Care Act, benefits, final regulations, health care reform, HHS, Ninth Circuit, nondiscrimination, regulations, Title VII, transgender, transition benefits
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged ACA, Affordable Care Act, correction, deadline, Form 1095-c, furnish forms, good faith, incomplete form 1095-c, incorrect form 1095-c, IRS, reasonable cause
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“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, … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged ACA, Affordable Care Act, health care reform, health plans, nondiscrimination, proposed regulations, transgender
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged ACA, ACA reporting, Affordable Care Act, deadline extended
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged ACA, ACA reporting, Affordable Care Act, information reporting, IRS forms
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 30-day extension, ACA, Affordable Care Act, draft instructions, Form 8809, information reporting, IRS, Section 6055, Section 6056
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, heatlth care reform, large employer penalties, large employer reporting, penalty increase, Section 6055, Section 6056, self-funded health plans, TPEA
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged ACA, Affordable Care Act, federal health care exchange, health care reform, king v. burwell, state health care exchange, Supreme Court, tax subsidy
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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. … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, employee hours, ERISA Section 510, full-time employees, health care reform, reduction in employee hours
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, Health Care, health care reform, health plans, Notice 2015-17
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