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Health Care Reform

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Over the years we have seen some employers, particularly small employers, choose to provide health coverage to their employees by paying all or part of the premium for individual insurance policies that the employees have obtained. Under an old IRS revenue ruling, Rev. Rul. 61-146, that type of premium subsidy could be provided on a …

On May 8, 2013, the Department of Labor (DOL) issued long-awaited temporary guidance and a model notice to be provided to employees about upcoming coverage options through the health care exchange, known as the Marketplace, established as a part of the health care reform legislation. This notice was originally supposed to be provided to employees …

Beginning in 2014, the employer shared responsibility mandate of the Patient Protection and Affordable Care Act requires applicable large employers (those employing on average at least 50 full-time equivalent employees on business days during the preceding calendar year (also see previous blog on determining if you are an applicable large employer) to offer minimum essential, …

The Department of Labor has published two checklists that plan sponsors can use to test their compliance with group health plan requirements. One checklist addresses the Affordable Care Act (ACA or health care reform) provisions, including a plan’s status as a “grandfathered” plan exempt from some ACA requirements, and such ACA requirements as limitations on …

Only applicable large employers may be assessed a penalty under the employer shared responsibility mandate of the Affordable Care Act.  An applicable large employer is defined by the regulations as one that has employed an average of at least 50 full-time employees (taking into account full-time equivalent employees or FTEs) on business days during the…

The Affordable Care Act requires most health plans to cover certain women’s preventive services, including contraception, without charging a co-pay or deductible. On January 30, 2013, the Obama Administration released proposed rules that continue to implement provisions in the health care law providing women contraceptive coverage without cost sharing, while at the same time respond…

In early January, the Internal Revenue Service published proposed regulations on “Shared Responsibility for Employers Regarding Health Coverage.”  These regulations incorporate the provisions of many previous Notices with some modifications, and also propose guidance on additional issues under the Patient Protection and Affordable Care Act.  The regulations provide rules and examples for determining: status as…

The Patient Protection and Affordable Care Act requires employers who issue 250 or more W-2s in a year to report the aggregate cost of coverage under an employer-sponsored group health plan in Box 12 of each employee’s Form W-2, using code DD. In general, the amount reported should include both the employer and employee-paid portions …

The Affordable Care Act establishes a Patient-Centered Outcomes Research Institute as a private nonprofit corporation to assist patients, clinicians, purchasers and policy makers in making informed health decisions using evidence based medicine. The Institute is to be funded through a trust fund called the Patient-Centered Outcomes Research Trust Fund. Under the Affordable Care Act, both …

Here’s a brief timeline highlighting important health care reform dates for employers…I expect some dates will change as 2014 draws nearer, and I will update the timeline accordingly.

9/23/12 – Group health plans must provide all eligible employees a standard Summary of Benefits and Coverage so members can compare medical plans.

12/31/12 – Form W-2…