The arrival of a new year marks the time to begin preparing annual 1095-C filings with the IRS and select state governments. Fortunately for employers, there aren’t any new 1095-C codes for the 2022 tax year. Still, with...more
On December 12, the IRS issued final regulations confirming the end of good-faith transition relief. The good news is that the regulations also include a permanent, automatic 30-day extension for Applicable Large Employers...more
The Internal Revenue Service (“IRS”) released final regulations... that permit employers to set aside pre-tax funds into health reimbursement arrangements (“HRAs”) that can be used by employees to pay for premiums and other...more
When reporting offers of coverage to full-time employees under the Affordable Care Act’s (ACA) employer shared responsibility rules, much of the detail appears in Part II of IRS Form 1095-C, Lines 14, 15 and 16. For the most...more
In Notice 2014-69, the Treasury Department and the IRS clarified that a group health plan that fails to provide substantial coverage for in-patient hospitalization and physician services will not be treated as providing...more
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
Under a common strategy for controlling group health care plan costs, employers sometimes adopt arrangements under which an employee is offered cash as an incentive to waive coverage. These arrangements are colloquially...more
As promised in the FAQ issued on March 30, 2015, the U.S. Departments of the Treasury, Labor and Health and Human Services (the Departments) have issued final regulations regarding the summary of benefits and coverage (SBC)...more
In this volume, we have collected the 52 weekly blog posts that comprise the series entitled, The Affordable Care Act—Countdown to Compliance for Employers. The series appeared in the Mintz Levin Employment Matters Blog...more
Over the last couple of months, we have followed and reported on a particular ACA compliance strategy under which an employer subject to the Affordable Care Act’s employer shared responsibility (or “pay-or-play”) rules...more
In a previous post, we described an Affordable Care Act compliance strategy—referred to commercially as a “minimum value plan” or “MVP”—that involves an offer of group health plan coverage that, while similar in most respects...more
Under the Affordable Care Act’s rules governing employer shared responsibility—which are codified in Internal Revenue Code § 4980H—where an applicable large employer makes an offer of group health plan coverage that is both...more
A recent Washington Post article (“Glitch in health care law allows employers to offer substandard insurance,” September 12, 2014) highlights an Affordable Care Act compliance strategy being marketed heavily (and adopted...more
Whether a group health plan provides minimum value is central to the application of the Affordable Care Act’s employer shared responsibility rules. The particulars of the role of minimum value in determining assessable...more
The federal health care reform law enacted in 2010, known as the Affordable Care Act, added a provision to the Internal Revenue Code (“Code”) (Code Section 4980H) that, beginning on January 1, 2015, may subject employers to...more
On February 25, 2013, the Department of Health and Human Services (HHS) released its final rule (the Final Rule) setting forth standards for health insurance issuers under the Patient Protection and Affordable Care Act (the...more
A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more