HDHP Telehealth Relief Extended for Remainder of 2022, but Mind the 3-Month Gap in Relief

On March 15, 2022, the Consolidated Appropriations Act, 2022 (the “2022 CAA”) was signed into law.  Section 307 of the 2022 CAA extends the relief permitting high deductible health plans (“HDHPs”) to provide telehealth and other remote care services free … Continue reading

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Group Health Plans Must Provide Free Over-the-Counter COVID-19 Tests Effective January 15, 2022

On January 10, 2022 the Departments of Labor, Health and Human Services, and Treasury issued Affordable Care Act FAQs Part 51 which addresses, in relevant part, payment for over-the-counter (“OTC”) COVID-19 testing.   For more information about the OTC COVID-19 testing and its … Continue reading

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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

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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

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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

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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

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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

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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

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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

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HIPAA Business Associates Agreements – Reminder of September 22 Deadline

On January 17, 2013, the U.S. Department of Health and Human Services (HHS) issued a final rule under HIPAA making substantial changes to the rules for vendors that provide services to HIPAA-covered plans, such as third-party administrators, pharmacy benefit managers … Continue reading

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