MARY E. POWELL, November, 2018 On October 29, 2018, the U.S. Departments of Labor (DOL), Treasury (“Treasury”) and Health and Human Services (HHS) (together, the “Departments”) issued proposed regulations that would allow a health reimbursement arrangement (HRA) to be used for the purchase of individual health insurance coverage and include an “excepted benefit” HRA that […]
TIFFANY N. SANTOS, December, 2017 Just before the start of the new year, the IRS issued Notice 2018-06, automatically extending to March 2, 2018 the due date for applicable large employers (generally those with 50 or more full-time employees) to furnish the Form 1095-C to full-time employees (pursuant to Section 6056 of the Internal Revenue […]
ERIC SCHILLINGER, October 2017 As published by Law360.com on October 19, 2017. On Oct. 12 President Donald Trump issued an executive order regarding the federal laws governing health care and insurance. The executive order itself does not change the existing rules. Rather, it instructs the applicable federal agencies — the U.S. Departments of Treasury, Labor, […]
MARY POWELL, August 2017 On August 16th, the U.S. Department of Health and Human Services (“HHS”) announced that it would make September cost-sharing reduction payments (“CSR Payments”) to health insurance carriers that offer eligible plans on the public insurance exchanges. CSR Payments are a key component of the Patient Protection and Affordable Care Act (“ACA”), […]
ERIC SCHILLINGER, August 2017 Originally published by Law360.com on August 4, 2017. In the early hours of Friday, July 28, Republican-led efforts to repeal and replace the Patient Protection and Affordable Care Act were rebuffed on the Senate floor. By roughly 1:40 a.m., three Republican Senators — Susan Collins, R-Maine, Lisa Murkowski, R-Alaska, […]
ERIC SCHILLINGER, June 2017 Originally published by Law360.com on June 28, 2017. On June 22, 2017, Senate Republicans unveiled a “discussion draft” of the Better Care Reconciliation Act of 2017 (BCRA), a bill that seeks to repeal, replace, revise or delay many of the federal health care laws enacted in 2010 by the […]
MARY POWELL, June 2017 On June 22, 2017, Senator Mitch McConnell released a draft of the Better Care Reconciliation Act (“BCRA”), which is the Senate’s version of a replacement bill of the Patient Protection and Affordable Care Act (“ACA”). An amended version of the BCRA was released on June 26, 2017. Process A Senate […]
ACA Replacement Clears Its First Hurdle: An Analysis of What’s Next (Trucker Huss Webinar on May 24)
ERIC SCHILLINGER, May 2017 On Thursday, May 4, the House of Representatives narrowly passed the American Health Care Act (AHCA), a budget reconciliation bill that would repeal and replace many provisions in the Patient Protection and Affordable Care Act (ACA) that relate to the individual insurance market, Medicaid and employer-sponsored group health plans (GHPs). […]
ERIC SCHILLINGER, March 2017 On Friday, March 24th, Speaker Paul Ryan cancelled a House of Representatives vote scheduled for that day on the American Health Care Act (AHCA), a bill that proposed to repeal, replace and revise various tax- and spending-related aspects of the Patient Protection and Affordable Care Act (ACA). As explained in […]
ERIC SCHILLINGER, March 2017 On Monday, March 6, the House Ways and Means Committee and Energy and Commerce Committee each released formal proposals partially repealing and replacing the Patient Protection and Affordable Care Act (the “ACA”). Signed into law in 2010 by then-President Barack Obama, the ACA significantly changed the federal laws governing health […]
TIFFANY N. SANTOS and SHANNON OLIVER, July 2016 — IRS Issues Early Affordable Care Act (“ACA”) Draft Forms 1094 and 1095-C for 2016 Coverage and New Proposed Rules for Section 6055 Reporting by Providers of Coverage In early July 2016, the IRS issued early drafts of the forms that applicable large employers must provide to […]
CALLAN CARTER and TIFFANY N. SANTOS, February 2016 – This article was updated March 8, 2016. In a welcome set of “Questions and Answers,” IRS Notice 2015-87 (the “Notice”) provides guidance on various employer group health plan topics. The Notice formalizes and clarifies previously issued FAQs and informal guidance for group health plans implementing the […]
JAHIZ AGARD and SHANNON OLIVER, December 2015 — On December 28, 2015, with deadlines looming, the Internal Revenue Service (“IRS”) released Notice 2016-4, extending the due dates for the information reporting required under Sections 6055 and 6056 of the Internal Revenue Code (the “Code”). Of significance to employers, the deadlines for furnishing the 2015 Forms […]
CLARISSA A. KANG, November 2015 — On November 18, 2015, the Department of Labor (“DOL”) published proposed regulations to update plans’ internal claims and appeals procedures for determining disability benefit claims. The proposal is meant to bring in line the adjudication of disability benefit claims with claims and appeals procedures for non-grandfathered group health plans […]
TIFFANY N. SANTOS, September 2015 — On September 16, 2015, after several draft iterations, the IRS issued the long awaited: Final 2015 Forms 1094-C and 1095-C (and related instructions) for “applicable large employers” to report coverage offered to their full-time employees to allow the IRS to determine whether the employer owes a payment under the […]
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