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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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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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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged EAP, employee assistance program, excepted benefits, final regulations, Health Care, health care reform, welfare plans
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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 … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Health Care, health care reform, health plans, HHS, reinsurance program, self-insured health plans
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Agencies Come Down Hard on Various Employer Health Plans and Arrangements
As we move into 2015, employers continue to grapple with numerous Health Care Reform concepts. Employers should be cautious regarding arrangements promoted to avoid health care penalties because the agencies are cracking down, as shown below. On November 4, 2014, … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Health Care, health care reform, HRAs, in-patient hospitalization, IRS, minimum essential coverage, minimum value coverage, skinny plans
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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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Subsidized Post-Termination COBRA Benefits
Nancy Campbell recently wrote a newsletter that discussed how health care reform impacts COBRA. One of the issues that Nancy addressed is subsidized COBRA and severance arrangements. The purpose of this blog is to dive deeper into the issues employers … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 409A, COBRA, Health Care, health care reform, health plans, post-termination medical, severance
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The IRS Meant What It Said in Notice 2013-54 – Employers Who Pay For Individual Health Insurance Policies for Employees On a Pre-Tax Basis Face Massive Penalties
In our 2013 End of Year Plan Sponsor “To Do” List Part 2 – Health and Welfare I did a lengthy summary of the various changes required to employer health care arrangements on account of IRS Notice 2013-54. On May … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged DOL, Health Care, health care reform, health plans, IRS, non-integrated HRA, Notice 2013-54
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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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