Affordable Care Act

Final 90-Day Health Plan Waiting Period Rules Issued

TIFFANY N. SANTOS, March 2014 — On February 24, 2014, the Internal Revenue Service (the “IRS”), Department of Labor and Department of Health and Human Services jointly issued the final regulations implementing the 90-day waiting period limitation under the Affordable Care Act (the “ACA”) and related proposed regulations, clarifying the extent to which an employer […]

IRS Issues Final Regulations Implementing the ACA’s Information Reporting Requirements under Code Sections 6055 and 6056

On March 1, 2014, the Internal Revenue Service (“IRS”) issued final regulations implementing the following information reporting requirements under the Internal Revenue Code (the “Code”) as added by the Affordable Care Act (the “ACA”): Section 6055 ( Requires health insurance issuers and sponsors of self-insured group health plans to report information to the IRS and […]

New Final Regulations Regarding Affordable Care Act’s Employer Mandate

ELIZABETH L. LOH and TIFFANY N. SANTOS — On February 12th, the Internal Revenue Service (“IRS”) published the much anticipated final regulations, and a helpful set of Questions and Answers, implementing the Affordable Care Act’s Employer Shared Responsibility Provisions under Section 4980H of the Internal Revenue Code (often referred to as the “Employer Mandate” or […]

Proposed Amendments Issued Expanding the Types of Benefits that May Be Excepted from the Affordable Care Act

On December 24, 2013, the Department of Labor, the Department of Treasury, and the Department of Health and Human Services (the “Departments”) issued a welcome set of proposed regulations regarding the treatment of certain “excepted benefits” under the Affordable Care Act (“ACA”). Excepted benefits are benefits that are exempt or excepted from the requirements of […]

Just in Time for 2014: New FAQ Grab-Bag Guidance Sheds Light on Numerous PPACA Issues

We’ve come a long way since March 23, 2010, the date President Obama signed the Patient Protection and Affordable Care Act (PPACA) into law. So far, in fact, that the tri-agency series of FAQ guidance has reached the age of majority in this latest FAQ XVIII. This seems appropriate, given that the law has now […]

New ACA Transitional Reinsurance Program Fee Proposed Rules Allowing for Installment Payments and a Limited Exemption for Self-Insured Self-Administered Plans

On December 2, 2013, the Department of Health and Human Services (“HHS”) published new proposed rules addressing the transitional reinsurance fee program (the “Reinsurance Program”) established under the Affordable Care Act (“ACA”) that will affect self-insured plans and health insurance issuers. The proposed rules would: exempt self-insured plans that do not use a third party […]

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