
Articles
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.
Common Misconceptions about the ACA Reporting Requirements
Monday, November 9, 2015
As we approach year-end, many employers realize that the 1094/1095 ACA reporting, which seemed to be so far off, is right around the corner. As we have talked with employers about these requirements, we have heard quite a few misconceptions.
PACE Act Changes the Definition of Small Group Insurance
Monday, October 12, 2015
President Obama has signed legislation recently passed by Congress which changes how “ small group” health insurance will be defined for rating and underwriting purposes.
IRS Clarifies No ACA Employer Reporting Required for Most HRAs
Thursday, September 24, 2015
On September 17, 2015, the IRS issued Notice 2015-68 which includes new guidance making it clear that employers who offer an HRA integrated with a regular health plan will not be required to provide any additional reporting specific to the HRA.
Cadillac Tax – 2015 IRS Notices
Thursday, September 17, 2015
The Internal Revenue Service (IRS) has released two separate notices this year requesting comments on how to administer the excise tax on high-cost health coverage (also known as the “Cadillac tax”) set to go into effect for the 2018 tax year.
Medicare Part D Notice Reminder
Tuesday, September 15, 2015
As you may recall, with the introduction of Medicare Part D prescription drug benefits, the Centers for Medicare and Medicaid Services (CMS) imposed certain notice requirements on employers. Employers are required to notify all Medicare beneficiaries of the “creditable” or “non creditable” coverage status of their prescription drug plan.
Employer Reporting – HRA Reporting Requirement
Thursday, September 3, 2015
In the recent draft instructions released by the IRS in regards to employer reporting on Forms 1094 and 1095, the IRS indicates that reporting is required for health reimbursement accounts (HRAs) integrated with fully-insured plans.
SDI Gains Marketshare in the Northwest
Monday, August 17, 2015
Subcontractor Default Insurance (SDI) has become a much more visible feature on major construction projects in the Northwest. Our region was arguably the last to embrace SDI.
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