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 …
Rip Van Winkle Health Care Reform Update
April 14, 2014 Leave a Comment
Have you been asleep for a while, like Rip Van Winkle, and just waking up to learn about health care reform? Or just not been interested in watching the minutiae of health care reform? Or have you just become responsible for health care reform compliance? We have plenty of posts about what you need to know, …
Delays in Employer Mandate
February 18, 2014 Leave a Comment
Recently, the U.S. Department of the Treasury issued final regulations under Section 4980H of the Affordable Care Act regarding implementation of employer responsibility provisions. Of particular note for medium‑sized employers, the regulations provide for a delay in enforcing the employer mandate for employers …
Controlled Group Issues Under the Pay-or-Play Rules
April 1, 2013 1 Comment
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 …
New Guidance on Measuring Full-Time Employee Status
September 4, 2012 1 Comment
Newly released IRS Notice 2012-58 describes the voluntary safe harbors that employers may use to identify full-time employees for purposes of the employer mandate. Employers who employ 50 full-time and full-time equivalent employees are subject to the mandate, and the number of full-time employees determines the …