The Affordable Care Act (ACA) has made a number of significant changes to group health plans since the law was enacted in 2010. Many of these key reforms became effective in 2014 and 2015, including health plan design changes, increased wellness program incentives and the employer shared responsibility penalties. Certain changes to some ACA requirements […]

On Dec. 31, 2016, the U.S. District Court for the Northern District of Texas issued a nationwide preliminary injunction temporarily blocking enforcement of the Section 1557 nondiscrimination rules under the Affordable Care Act (ACA). The court’s injunction specifically bans the Department of Health and Human Services (HHS) from enforcing the Section 1557 provisions prohibiting discrimination […]

On Dec. 28, 2015, the Internal Revenue Service (IRS) issued Notice 2016-4 to delay the due dates for filing and furnishing forms under Section 6055 and 6056. • The due date for furnishing forms to individuals has been extended from Feb. 1, 2016, to March 31, 2016. • The due date for filing forms with […]

On Dec. 18, 2015, President Barack Obama signed a federal budget bill for 2016 into law, which makes significant changes to three tax provisions under the Affordable Care Act (ACA). This new law: 1. Delays implementation of the ACA’s Cadillac tax on high-cost group health coverage for two years, until 2020; 2. Imposes a one-year […]

On Dec. 16, 2015, the Internal Revenue Service (IRS) issued Notice 2015-87 to address how certain provisions under the Affordable Care Act (ACA) apply to employer-provided health coverage. The notice covers the ACA’s market reforms as well as the employer shared responsibility rules and related reporting requirements. Key provisions of the notice include: 1) Confirmation […]

The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056. Under these new reporting rules, certain employers must provide information to the IRS about the health plan coverage they offer (or do not offer) to their employees. On Feb. 8, 2015, the Internal Revenue Service (IRS) released […]

In the past, many employers have helped employees pay for individual health insurance policies instead of offering an employer-sponsored plan. In recent months, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) have released several pieces of guidance addressing these arrangements. The Departments’ guidance specifically addresses “employer payment plans,” under […]

Due to the rising costs of health coverage, employers have shown interest in helping employees pay for individual health insurance policies instead of offering an employer-sponsored plan. In response, on Nov. 6, 2014, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) issued FAQ guidance clarifying that these arrangements do […]

The Affordable Care Act (ACA) imposes a dollar limit on employees’ salary reduction contributions to a health flexible spending account (FSA) offered under a cafeteria plan. This limit first became effective for plan years beginning on or after Jan. 1, 2013. The ACA set the health FSA contribution limit at $2,500. For years after 2013, […]