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Documents on Employee Benefits, Health Care
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|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:
|The Affordable Care Act—Countdown to Compliance for Employers, Week 18: Emerging Strategies to Reduce or Eliminate Exposure for Assessable Payments under the Affordable Care Act’s Pay-or-Play Rules|
Alden J. Bianchi; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
September 2, 2014, previously published on August 25, 2014The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health plan coverage (i.e., “play”) or...
|Healthcare Reform in the U.S. Territories; Prepayment of Taxes for Puerto Rico Retirement Plans|
Karen N. Brandon, Grace Huang Ristuccia; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
September 1, 2014, previously published on August 28, 2014The summer of 2014 has brought further guidance for health plan coverage in the U.S. territories and for retirement plan coverage in Puerto Rico. Issuers and employer sponsors of Puerto Rico group health plans and employer sponsors of Puerto Rico retirement plans should review their plans to ensure...
|Two Important Deadlines Approaching for Self-Insured Group Health Plans|
Casey K. Fleming, Leigh C. Riley; Foley & Lardner LLP;
September 1, 2014, previously published on August 26, 2014If you sponsor a self-insured group health plan, then November includes two important deadlines: (1) you must obtain a health plan identifier for your plan, and (2) you must report the number of participants for whom a transitional reinsurance fee is due.
|Resistance WAS Futile—California Conforms to ACA Waiting Period Requirement|
Timothy G. Verrall; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
August 29, 2014, previously published on August 20, 2014After wandering in the wilderness for a year, California has now come in from the cold and conformed its requirements for eligibility waiting periods to the federal standard adopted in the Affordable Care Act (ACA). Effective January 1, 2015, SB 1034 imposes a 90-day limit on eligibility waiting...
|Health Care Reform: Employers Should Prepare Now for 2015 to Avoid Penalties|
Jackson Lewis P.C.;
August 12, 2014, previously published on August 8, 2014Under the Patient Protection and Affordable Care Act, beginning in 2015, certain large employers who do not offer affordable health insurance that provides minimum value to their full-time employees may be subject to significant penalties. These penalties are explained below.
|Big Increase in 2014 Service Contract Act Health & Welfare Rate Announced|
Jackson Lewis P.C.;
July 31, 2014, previously published on July 28, 2014The U.S. Department of Labor (DOL) has released its annual memorandum with the rate increase for Service Contract Act (SCA) Health and Welfare (H&W) Fringe Benefits. The new rate of $4.02 per hour (up from last year’s $3.81 per hour) is required in all government contract bids or other...
|The Affordable Care Act—Countdown to Compliance for Employers, Week 22: Charting the Future of the Premium Subsidies (and Employer Penalties): Halbig v. Burwell and King v. Burwell|
Roy M. Albert, Alden J. Bianchi, Stephen M. Weiner; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
July 29, 2014, previously published on July 28, 2014On July 22, 2014, two federal appellate courts issued conflicting decisions, within hours of each other, regarding the IRS final rule published on May 23, 2012 (the “IRS Rule”), intended to implement the exchange-related tax credit provisions of the Affordable Care Act...
|Federal Government Report on Data Breaches in Health Care|
Margaret Young Levi; Wyatt, Tarrant & Combs, LLP;
July 28, 2014, previously published on July 21, 2014The U.S. Department of Health and Human Services, Office for Civil Rights (OCR) has issued two reports to Congress required by Section 13402(i) of the Health Information Technology for Economic and Clinical Health (HITECH) Act: