Affordable Care Act, Self-Funded Health Plans, Employer Group Health Plans

Summer's Hot Debate: Does a Self-Funded Group Health Plan Cover Gender-Affirming Care?

Bricker Graydon LLP on 7/17/2024

As the temperatures continue to rise, regulations and litigation related to employer-sponsored group health plans have followed suit. As these new rules continue to evolve, we are often asked whether a self-insured group...more

Group Medical Captives, Level Funding and US Healthcare Policy

McDermott Will & Emery on 6/19/2024

In a recent article in Managed Healthcare Executive, Peter Wehrwein examines the trend of self-funding of group health benefits by smaller employers who used to depend mainly or entirely on fully insured programs....more

Can a Self-Funded Group Health Plan Exclude Coverage for Gender-Affirming Care?

Verrill on 5/28/2024

We are sometimes asked whether a self-funded group health plan is required to cover gender-affirming medical services. As this post explains in detail, it is generally impracticable for a self-funded ERISA-covered plan to...more

Compliance Alert: CAA, 2023 Eliminates MHPAEA Exemption for Self-Funded Non-Federal Governmental Health Plans

Woodruff Sawyer on 1/13/2023

On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023 (“CAA, 2023”), into law. The CAA, 2023, which is largely a bipartisan spending bill, sunsets provisions of the Public Health Service Act...more

A Guide For Employers To The American Rescue Plan Act

Fox Rothschild LLP on 3/16/2021

The American Rescue Plan Act of 2021 is an enormous and intricate piece of legislation that has direct consequence for employers. Signed into law by President Joe Biden on March 11, 2021, ARPA mandates several important...more

Association Health Plans: Self-Funded vs. Fully-Insured

Mintz - Employment Viewpoints on 2/12/2018

Recently proposed Department of Labor (Department) regulations governing Association Health Plans (AHPs) would, if made final, permit small employers to be regulated under more favorable, large group rules. The proposed...more

Thank You IRS - Extensions for This Year’s ACA Tax Reporting

Foley & Lardner LLP on 1/11/2018

The “Bottom Line” - Employers will have until March 2, 2018 to furnish Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”) to employees.,,...more

Association Health Plans: What Are They & What’s Changing?

Nilan Johnson Lewis PA on 10/17/2017

What are Association Health Plans? Association Health Plans allow small employers or self-employed individuals to group together to form a larger pool for offering health insurance. An Association Health Plan model can...more

Association Health Plans—Can The Trump Administration Expand Access Without Congress?

Mintz - Employment Viewpoints on 10/13/2017

In recent weeks, the Trump Administration has been considering allowing health insurance to be purchased across state lines and expanding access to “Association Health Plans” (AHPs) that could take economic advantage of...more

Court Throws Monkey Wrench Into Wellness Programs

Proskauer - Employee Benefits & Executive... on 8/23/2017

The U.S. District Court for the District of Columbia has ordered the EEOC to reconsider its final regulations on the extent to which an employer may offer incentives to participate in a wellness program without violating the...more

The Rise of the Group Health Insurance Captive

Mintz - Employment Viewpoints on 6/15/2017

With its “employer mandate”—i.e., the requirement that applicable large employers make an offer of group health coverage to substantially all full-time employees or face the prospect of a penalty—the Affordable Care Act (ACA)...more

IRS Addresses ACA Reporting Requirements Self-Funded Plans, HRAs

BCLP on 9/7/2016

As promised in Notice 2015-68, the IRS has proposed clarifications to the regulations under IRC Section 6055 relating to information reporting rules for minimal essential coverage providers. These rules affect employers...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

Mintz - Employment, Labor & Benefits... on 10/29/2015

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

Mintz - Employment, Labor & Benefits... on 9/22/2015

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

More Cadillac Plan Tax Guidance from IRS

Balch & Bingham LLP on 8/7/2015

Code § 4980I (a/k/a/ the “Cadillac Plan tax”) was added by the ACA so that taxpayers with average group health plans would not subsidize, by tax preference, rich plans benefitting chiefly the rich. Section 4980I imposes a...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 2 of 24): Yikes! The Costs of Failing to Comply...

Mintz - Employment, Labor & Benefits... on 7/27/2015

The Affordable Care Act (ACA) imposes information reporting rules on providers of minimum essential coverage, e.g., insurance carriers and self-funded plans, and on applicable large employers, i.e., those employers that are...more

Patient Protection and Affordable Care Act (PPACA) › Self-Funded Health Plans › Employer Group Health Plans