
Articles
Form 1095 Deadline and Penalties
Tuesday, March 22, 2016
As part of the ACA employer reporting requirements, certain employers must provide a Form 1095-C or 1095-B to all applicable employees by March 31, 2016. Employers subject to employer reporting requirements who fail to provide the required Form 1095s by the deadline may face penalties similar to those imposed for W-2 reporting.
Background
Proposed Revisions to SBC and Uniform Glossary
Tuesday, March 15, 2016
On February 22, 2016, the Departments of Labor, Treasury, and Health and Human Services (“the Departments”) released proposed updates to the Uniform Summary of Benefits and Coverage (SBC) template, instructions, and Uniform Glossary (“glossary”). The proposed documents build largely on the revisions first proposed in December 2014. However, they incorporate additional stakeholder feedback—primarily from the NAIC—and the Departments are requesting public comments through the end of March before the documents are finalized.
Does Your Firm Have a Network Breach Plan?
Friday, March 4, 2016
Your IT Department has assured the latest updates and patches are in place for your firm’s network and your technology consultants are confident the system is set to prevent a hacking attack. But, just in case, your firm has recently purchased “cyber liability” insurance.
Social Engineering Criminals May Be Targeting Your Organization: Are You Vulnerable?
Tuesday, March 1, 2016
Human-based social engineering fraud (sometimes referred to as human hacking) is defined as the art of influencing people to disclose information and getting them to act inappropriately.
Form 1095 – Employee Communications
Friday, February 5, 2016
Many employers want to provide some type of communication along with or before the distribution of Form 1095s to relevant employees. Although any employee communication must be tailored to meet the employer’s specific circumstances, some general concepts are addressed here that can be adjusted as appropriate to help employees understand why Form 1095s are being provided, what type of information they provide, and how they are to be used.
Preparing For The Snow
Friday, January 22, 2016
That preparation should include a review of the business’ insurance portfolio, specifically the ingress & egress coverage, and civil authority coverage of the business’s property policy.
Most standard property policies usually only cover loss “caused by direct physical loss of or damage to property.” Therefore, if a company has a roof collapse due to heavy snow load, it is likely the building and the resulting interruption of business would be covered by the policy. However, if the building or property is not damaged, and the business cannot operate due to the inability of access to the plant, building, or facility due to the weather, is that a covered loss under the property policy? The answer is, “It depends.”
How to Prepare for a Data Breach in Healthcare
Wednesday, January 20, 2016
To ensure proper data breach response preparedness (and to show proper due diligence), your directors and leadership staff should be asking I.T. and key partners the pertinent questions now, before a breach occurs:
Have we ever had system penetration testing done, and have we reviewed the results?
Cadillac Tax – Delayed
Monday, January 11, 2016
In December, the Consolidated Appropriations Act, 2016 was signed into law which, amongst other provisions, effectively delayed the excise tax on high-cost health coverage (also known as the “Cadillac Tax”) until January 1, 2020. In addition, the law made the excise tax deductible and provides for a study to determine whether appropriate age and gender benchmarks are being used to determine the Cadillac tax threshold adjustments.
IRS Releases Broad Range of Guidance in Notice 2015-87
Thursday, January 7, 2016
To end 2015, the IRS released Notice 2015-87, which provides guidance on a broad range of employee benefits compliance issues. The guidance is provided in a question-and-answer format, with comments requested on several issues that the IRS plans to address in forthcoming rules. The Notice supplements previous guidance on several issues, including Health Reimbursement Arrangements (HRAs) and Employer Payment Plans, providing additional clarification and, in some cases, transition relief or grace periods for compliance. It also builds upon existing regulations with respect to affordability; issues related to the employer shared responsibility provisions in Section 4980H and related reporting requirements; health flexible spending arrangements (health FSAs); health savings accounts (HSAs); and COBRA.
IRS Released Additional §4980H Guidance
Wednesday, December 30, 2015
In mid-December, the Internal Revenue Service (IRS) released further guidance on a variety of Affordable Care Act (ACA) provisions that affect employer-sponsored group health plans via Notice 2015-87. The notice was provided in a Q&A format, with several of the responses clarifying §4980H (“employer mandate”) requirements, including guidance in regard to determining affordability, counting hours of service, and 2016 penalty (assessable payment) amounts.
IRS Extends Deadline for Employer ACA Reporting
Tuesday, December 29, 2015
The IRS has issued Notice 2016-4 extending the due date for employers to complete their 2015 ACA Form 1095 and 1094 reporting.
EEOC Issued GINA Wellness Rules
Monday, November 9, 2015
On Friday, October 30, the Equal Employment Opportunity Commission (EEOC) issued proposed rules that would amend the regulations implementing Title II of the Genetic Information Nondiscrimination Act (GINA). These rules relate to incentives offered in exchange for health information about an employee’s spouse as part of an employer-sponsored wellness program. The proposed rules provide a narrow exception to the prohibition on incentives that are contingent on the provision of genetic information.
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