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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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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 6055, 6056, Affordable Care Act, Health Care, health care reform, large employer reporting
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Proposed Regulations for Summary of Benefits and Coverage Seek to Simplify Compliance
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, group health plan, health care reform, proposed regulations, SBC, summary of benefits and coverage
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Health Care Reform 2015 – An Update
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, Health Care, health care reform, health plans, king v. burwell, large employer penalties
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, Health Care, health care reform, minimum essential coverage, reporting
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November 15 Deadline for Self-Insured Health Plans 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. The contribution amount is determined by the number of covered lives … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, health care reform, health plans, reinsurance, self-insured
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Final Regs on Health Care Reform Large Employer Penalties May Help Employers Who Hire Employees From Staffing Firms
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, final regulations, Health Care, health care reform, health plans, large employer penalties, MEC, minimum essential coverage
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Do you know who is in your controlled group? Employers need to know for purposes of the large employer shared responsibility penalties
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., … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, controlled group, Health Care, health care reform, health plans, large employer penalties
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Non-integrated health reimbursement arrangements (whatever they are called) are subject to $36,500 per-participant per-year penalty
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, Health Care, health care reform, health plans, health reimbursement arrangements, HRAs
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What the heck is MEC?
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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Affordable Care Act, final regulations, health care reform, MEC, minimum essential coverage
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Final Regs on Health Care Reform Large Employer Penalties Keep Many Transition Rules
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 … Continue reading
Posted in Employee Benefits, Health Care Reform
| Tagged Affordable Care Act, final regulations, health care reform, IRS
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