On February 12, 2014, the Treasury Department issued final regulations for the employer shared responsibility (“pay or play”) requirement under the Affordable Care Act (proposed regulations were issued in December of 2012). The regulations provide a large number of clarifications and transition relief – this article highlights several important transition relief provisions that employers should
Understanding Employee Benefits and key developments in the employee benefits field and items of interest to our clients. MORE
Health Care Reform
More About HRAs and Some About EAPs
By Stinson LLP on
I blogged recently about IRS and Department of Labor (DOL) guidance restricting the ability of employers to subsidize individual health insurance premiums for their employees after December 31, 2013. That IRS and DOL guidance also addressed a few other issues. The guidance provides that HRA amounts credited to an employee can be used to determine …
Certain Plan Designs Will Cost More Under the Patient-Centered Outcomes Research Institute Fees
By Stinson LLP on
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 …
HEALTH CARE REFORM – IMPLEMENTATION TIMELINE FOR EMPLOYERS (subject to change as additional guidance is issued)
By Stinson LLP on
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…
Health Care Reform – What Employers Should be Thinking About Now
By Stinson LLP on
Beginning in 2014, the Affordable Care Act will require employers employing 50 or more full-time equivalent employees to offer full-time employees affordable, minimum essential health coverage. If such health coverage is not offered, and if at least one employee receives a premium tax credit on a state or federal exchange, the employer will be assessed…
IRS Issues Guidance on $2,500 Limit on Health FSAs
By Stinson LLP on
Under the Health Care Reform Act, health flexible spending arrangements under cafeteria plans are limited to $2,500 in salary reduction contributions beginning in 2013. Employers with plan years that were not calendar years have been wondering how the limit would be applied. The IRS has now issued guidance in the form of Notice 2012-40 with …
IRS Issues Guidance on W-2 Reporting of Health Care Coverage
By Stinson LLP on
The IRS issued recently FAQs relating to W-2 reporting of employer-provided health care coverage, a health care reform requirement that employers must first meet for the 2012 calendar year. We have previously discussed these requirements [Link to earlier health care reform posts]. These FAQs largely restate prior guidance.
The IRS also released an article on …
March 2011 Developments – Delay of Federal Enforcement of Claims Procedures and Change in State Income Taxation of Health Benefits in Minnesota
By Stinson LLP on
This is the twelfth in a series of articles about health care reform.
One year after the enactment of the health care reform legislation on March 23, 2010, changes are still being made on both the federal and state levels. This article addresses one recent federal policy and one state law change from the State…
In Holiday Spirit, IRS Defers Nondiscrimination Requirement for Insured Health Plans
By Stinson LLP on
This is the eleventh in a series of articles about health care reform.
In October of this year, we published an article, available here, describing the new health care reform requirement that non-grandfathered fully insured health plans must not discriminate in favor of highly compensated individuals. We mentioned that it was unclear how that…
Stiff Penalties for Paying Disproportionate Share of Executive’s Premiums
By Stinson LLP on
This is the ninth in a series of articles about health care reform.
This article addresses a provision of the Health Care Reform Law that has not gotten as much press as some of the other provisions, such as the requirement to cover adult children to age 26 or the elimination of lifetime limits on…