Starting in 2014, the “pay-or-play” rules under Internal Revenue Code section 4980H will apply to large employers who employ an average of 50 full-time or full-time equivalent employees. Proposed regulations released earlier this year provide important details regarding how the 4980H rules apply to …
Health Care Reform FAQs Address Women’s Preventive Services
March 7, 2013 Leave a Comment
As we discussed in an earlier post, non-grandfathered group health plans must cover certain women’s preventive services without cost-sharing for plan years beginning on or after August 1, 2012 (which would be January 1, 2013 for calendar-year plans). Several of the FAQs in the recently released 12th set of …
Agencies Issue New Wellness Regulations
November 26, 2012 Leave a Comment
Last week, the IRS, DOL and HHS (the “Departments”) published proposed rules amending the regulations regarding nondiscriminatory wellness programs in group health plan coverage proposed regulations. Consistent with the Affordable Care Act, the proposed regulations increase the maximum allowable reward for a …
Looking Ahead to 2013: Coverage of Women’s Preventive Services
October 29, 2012 Leave a Comment
With 2013 right around the corner, one new requirement that will be in effect on January 1 for calendar-year non-grandfathered group health plans is the coverage of certain women’s preventive services without cost-sharing. The coverage requirement is effective for plan years beginning on or after August 1, …
Summary of Benefits and Coverage Now in Effect
October 1, 2012 Leave a Comment
With fall open enrollment season upon us, group health plan sponsors should remember that the new Summary of Benefits and Coverage (“SBC”) requirements are now in effect. The first SBC must be provided to participants and beneficiaries for enrollment or re-enrollment periods beginning on or after September …
District Court Holds That Michigan Tax on Benefit Payments is Not Preempted By ERISA
September 11, 2012 Leave a Comment
We previously addressed the passage of Michigan’s Health Insurance Paid Claims Assessment Act (“Act”), which imposes a 1% tax on claims paid by health insurance carriers, and the subsequent legal challenge to that law by the Self-Insurance Institute of America (“SIIA”) in SIIA v. Snyder. On August 31, …