Form 720 Revised for PCOR Fee Reporting Under Health Care Reform

As previously discussed, health care reform established a new Patient-Centered Outcomes Research Institute (“PCORI”) to study patient-centered outcomes, funded by a Patient-Centered Outcomes Research (“PCOR”) fee.  This fee must be reported on Form 720 annually for seven years, beginning with the plan …

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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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IRS Issues Proposed Regulations on Compensation Deduction Limit for Health Insurers

The health care reform provision affecting health insurance providers limits deductions these providers may take for compensation paid for tax years beginning in 2013.  The provision limits deductions for compensation paid to any individual to $500,000 annually, with the limitation applied to compensation in the …

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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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Agencies Issue New Wellness Regulations

Agencies Issue New Wellness Regulations

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 …

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State Health Insurance Exchange Deadlines Extended

As we previously discussed, PPACA requires each state to establish a health insurance exchange by January 1, 2014, and if a state chooses not to do so, HHS will step in and administer that state’s exchange.  Originally, states were required to notify HHS of their intent to set up an Exchange (and to submit an …

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