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 …
ACA Requires All Health Plans to Obtain Health Plan Identifier (“HPID”)
March 6, 2014 Leave a Comment
Under health care reform, health plans are now required to obtain a Health Plan Identifier number (“HPID”). Under the HPID final regulations (published on September 5, 2012), large health plans must obtain an HPID by November 5, 2014. Small health plans with $5 million or less in annual receipts have an …
“Excepted Benefits” Status of EAPs
January 30, 2014 Leave a Comment
Last month, the IRS issued proposed regulations regarding what would be considered “excepted benefits” under ERISA, the Internal Revenue Code, and the Public Health Service Act, and therefore exempt from many health care reform mandates. One of the highlights of the regulations was the additional guidance …
Form 720 Revised for PCOR Fee Reporting Under Health Care Reform
June 7, 2013 Leave a Comment
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 …
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 …
Health Care Reform FAQs Address HRAs
January 29, 2013 1 Comment
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 …