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 (http://www.gpo.gov/fdsys/pkg/FR-2014-03-10/pdf/2014-05051.pdf): Requires health insurance issuers and sponsors of self-insured group health plans to report information to the IRS and […]

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 […]

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 […]

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 […]

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 […]