On December 28, the IRS issued Notice 2016-4, in which it delayed the deadline for filing 2015 Forms 1094 with the IRS and providing 2015 Forms 1095 to individuals. This will likely come as a great relief to many employers who have been figuring out how to complete these new forms, which are required to comply …
FTC Remains Focused on Health Care in 2015
April 20, 2015 Leave a Comment
The Federal Trade Commission (FTC or Commission) recently published its annual highlights, revealing that health care remains a top priority for the Commission. The FTC reported that nearly half of its enforcement actions for the preceding five years focused on the health care industry, including …
Insurer’s Agreements with Providers Are Not Per Se Antitrust Violations
March 6, 2015 Leave a Comment
The Iowa Supreme Court refused to categorize a health insurer’s agreements with providers in Iowa and its participation in the national Blue Cross and Blue Shield (BCBS) network as per se violations of the antitrust laws. In its decision in Mueller v. Wellmark, Inc. issued on February 27, 2015, the court …
Ninth Circuit Upholds Ruling for FTC in Hospital Merger Challenge
February 10, 2015 Leave a Comment
The Ninth Circuit upheld a district court’s ruling ordering St. Luke’s Health System to unwind its purchase of the Saltzer Medical Group. The decision is another victory for the Federal Trade Commission (FTC) in its renewed focus on potential competition concerns in health care. The FTC originally sued to …
New Guidance on Employment-Based Orientation Periods
July 1, 2014 Leave a Comment
As employers who sponsor group health plans well know, health care reform prevents plans from imposing waiting periods in excess of 90 days for employees who are otherwise eligible to enroll in a plan. The latest guidance relating to the waiting-period rules addresses the boundaries of “reasonable and bona …
Pay-or-Play: Think Globally
June 9, 2014 Leave a Comment
With the effective date of the “pay-or-play” employer mandate just over the horizon, employers who sponsor group health plans are well aware of the layers of complexity presented by the mandate. One of the layers that employers should be sure to unpack: how do the rules affect expatriate (expat) and …