New Guidance on Employee Notice of Exchanges

On May 8, the DOL issued eagerly anticipated guidance regarding the notice of health insurance exchanges that employers must distribute to employees during 2013, including model notices that employers may use to satisfy the notice obligation. The first model notice applies to employers who offer a health plan …

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Final Regulations on Transitional Reinsurance Program Fees

Starting in 2014, the new transitional reinsurance program will require self-insured group health plans and health insurance issuers to pay per-enrollee fees each year for three years.  In March, the Department of Health and Human Services released final regulations that confirm a number of important details …

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Top Five Issues for Multiemployer Plans and Health Care Reform

In the context of multiemployer plans, the application of various provisions of health care reform is murky.  Below are five issues that are top of mind for multiemployer plans: 1.   Pay or Play Penalty. The “pay or play” penalty applies to employers beginning in 2014.  The recent January 3, 2013 …

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Minnesota Health Insurance Exchange Coming Soon

Minnesota is on the brink of passing a law that would establish a Minnesota health insurance exchange. The "Minnesota Insurance Marketplace Act" passed the Minnesota legislature and is on its way to Governor Dayton's desk for signature. He is expected to sign the bill. Minnesota is one of only 18 states that have …

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Health Care Reform FAQs Address HRAs

Last week, the DOL, HHS, and Treasury jointly issued the 11th set of FAQs relating to health care reform.  In addition to delaying the employer Notice of Health Insurance Exchanges, which we addressed in a recent post,  the FAQs discussed a few other matters, including certain issues relating to health …

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Employer Notice of Health Insurance Exchanges Officially Delayed

As anticipated in our earlier post, the DOL has officially delayed the Notice of Health Insurance Exchanges.  We’ll provide more analysis of the most recent DOL FAQs in later posts, but Q1 of the 11th set of DOL health care reform FAQs states that employers are not required to provide the Notice by March 1, …

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