TIFFANY N. SANTOS and SHANNON OLIVER, November 2016 In a welcome surprise, the Internal Revenue Service (the “IRS”) on November 18, 2016, released Notice 2016-70 which delays the deadline from January 31, 2017 to March 2, 2017 for employers to furnish the Form 1095-C to full-time employees and for providers of health coverage (such as […]
Health and Welfare Plans
MARY E. POWELL and JENNIFER TRUONG, May 2016 — The Equal Employment Opportunity Commission (“EEOC”) issued final wellness plan rules under Title I of the Americans with Disabilities Act (“ADA”) and Title II of the Genetic Information Nondiscrimination Act (“GINA”) on May 16, 2016. The ADA rule focuses on wellness plan incentives for an employee […]
MARY E. POWELL and JENNIFER TRUONG, May 2016 — Health Savings Accounts (“HSA”) are an increasingly popular savings arrangement that allows enrollees to pay for certain out-of-pocket medical expenses on a tax-favored basis. Although there are many rules that govern HSA eligibility and contribution limits, one way an individual loses eligibility to contribute is if […]
ELIZABETH LOH, April 2016 – Introduction On March 21, 2016, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) launched Phase Two of its Health Insurance Portability and Accountability Act (“HIPAA”) Audit Program. In this phase of the HIPAA Audit Program, the OCR intends to audit a wide variety of covered […]
ROBERT R. GOWER and ERIC J. SCHILLINGER, January 2016 — On December 9, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-86, providing guidance on the application of the June 26, 2015 United States Supreme Court decision in Obergefell v. Hodges (“Obergefell”) to qualified retirement plans under Internal Revenue Code (“Code”) section 401(a) and health […]
JAHIZ NOEL AGARD, December 2015 — On October 30, 2015, the U.S. Equal Employment Opportunity Commission (EEOC) released proposed regulations on Title II of the Genetic Information Nondiscrimination Act (GINA) that reverse a prior position prohibiting wellness programs from requiring an employee to provide his genetic information (which includes information about a spouse or other […]
JENNIFER TRUONG, September 2015 — On September 1, 2015, the Internal Revenue Service (“IRS”) issued new proposed regulations on the determination of whether an employer-sponsored health plan provides “minimum value,” for purposes of the employer “offer of coverage requirement under Section 4980H of the Internal Revenue Code Under the proposed regulations and consistent with IRS […]
San Francisco
135 Main Street
9th Floor
San Francisco, CA 94105-1815
T: 415-788-3111
F: 415-421-2017
Los Angeles
15760 Ventura Boulevard,
Suite 910
Los Angeles, CA 91436-3019
Portland
329 NE Couch Street,
Suite 200
Portland, OR 97232-1332
