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Documents on Employee Benefits, Health Care
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|Final Regulations Regarding Limited Scope Vision and Dental Benefits and Employee Assistance Programs as Excepted Benefits|
Dan Brown, Kenneth B. Schnoll; Dentons Canada LLP;
November 17, 2014, previously published on October 1, 2014On October 1, 2014, the US Department of Treasury issued final regulations (the "Regulations") regarding limited-scope vision and dental benefits and employee assistance programs as excepted benefits for purposes of the Affordable Care Act.
|Legislation Imposing Limits on Direct Dispensing of Medications to Injured Workers by Physicians Becomes Law in Pennsylvania|
Francis X., Esq. Wickersham; Marshall Dennehey Warner Coleman Goggin P.C.;
November 15, 2014, previously published on November 3, 2014On October 27th, Governor Tom Corbett signed into law House Bill 1846, which will limit the practice of physicians dispensing drugs directly to injured workers. A recent front page article in The Philadelphia Inquirer by Don Saptkin highlighted the significant costs Pennsylvania employers were...
|IRS Announces Changes to Mid-Year Cafeteria Plan Elections|
Lauren B. Dunn; Foster, Swift, Collins & Smith, P.C.;
November 14, 2014, previously published on October 28, 2014On September 18, 2014, the Internal Revenue Service ("IRS") issued Notice 2014-55, that expands the permissible mid-year election change rules for cafeteria plans in order to facilitate enrollment in coverage through a Health Insurance Marketplace ("Marketplace"). Notice 2014-55...
|No Data from Self-Insured Plans|
Mary L. Porter; Gordon Feinblatt LLC;
October 17, 2014, previously published on Fall 2014The U.S. Court of Appeals for the Second Circuit recently held in Liberty Mutual v. Donegan that the federal Employee Retirement Income Security Act (ERISA) prohibits states from requiring self-insured health plans and their third party administrators to provide participant eligibility and claims...
|The Affordable Care Act—Countdown to Compliance for Employers, Week 13: IRS Notice 2014-49 Offers Useful Guidance on Changes in Measurement Periods or Changes in Testing Methods|
Alden J. Bianchi; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
October 6, 2014, previously published on September 29, 2014For purposes of complying with the Affordable Care Act’s employer shared responsibility rules (which are codified in Internal Revenue Code § 4980H), employers must identify their “full-time employees.” Final regulations issued under Code § 4980H provide two principle...
|The Affordable Care Act: Focus on Adjunct Faculty|
Patricia A. Moran; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
October 6, 2014, previously published on October 1, 2014The concepts of “hours of service” and “full time” loom large in the Affordable Care Act’s “employer shared responsibility” mandate (also known as the “employer mandate” or “pay or play mandate” and which we discussed in various...
|Final Rules on Compensation Deduction Limit for Health Insurers|
Dennis L. Allen, Adam B. Cohen, Thomas A. Gick, Michael A. Hepburn, Paul R. Lang; Sutherland Asbill & Brennan LLP;
September 29, 2014, previously published on September 25, 2014The Internal Revenue Service (IRS) and the Department of Treasury (Treasury) have issued final regulations under section 162(m)(6) of the Internal Revenue Code of 1986, as amended (Code), which limit the deduction certain health insurers may claim for compensation payable to their employees and...
|IRS Finalizes and Clarifies Obamacare Reporting Rules|
Barry L. Klein; Blank Rome LLP;
September 25, 2014, previously published on September 2014Action Items: The IRS has finalized and clarified the ObamaCare health care coverage reporting requirements for “applicable large employers.” The reporting requirements are effective for 2015. Major system changes will likely be necessary in order to track all of the information that is...
|The Affordable Care Act—Countdown to Compliance for Employers, Week 16: So What, Exactly, is an “Offer of Coverage”?|
Alden J. Bianchi, Edward A. Lenz; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
September 12, 2014, previously published on September 8, 2014Whether an employer makes the requisite offer of group health plan coverage is critical to the application of the Affordable Care Act’s employer shared responsibility rules as reflected in final implementing regulations issued earlier this year (and see here for a useful IRS summary of those...
|End of Year Planning and Compliance Deadlines for Health Plans|
Bret Busacker, John Franklin Clark; Holland & Hart LLP;
September 2, 2014, previously published on August 29, 2014Now that fall is in the air and school has started, we thought this would be a good time to summarize some of the key health and welfare benefit deadlines that are approaching this fall: