Health care reform’s rules on emergency services have been in effect since 2011, but group health plan sponsors would do well to keep them top-of-mind when crafting initiatives to promote proper emergency room usage. To review, the rules on emergency services apply to non-grandfathered, self-insured group …
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 …
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 …
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 …
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 …