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 …
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 …
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, …
New Guidance on PPACA’s Out-of-Pocket Maximum
January 31, 2014 Leave a Comment
This post will provide an overview of the new guidance on PPACA’s out-of-pocket maximum issued jointly by the HHS, the DOL, and IRS. This guidance is particularly important for plan sponsors who provide essential health benefits (EHBs) through multiple vendors. While previous guidance provided transitional …
Sunshine – Lessons From the First Two Months of Tracking Payments
October 15, 2013 Leave a Comment
The first two-plus months of tracking payments under the Physician Payment Sunshine Act are now in the rearview mirror. Though novel questions continue to arise (albeit with less frequency), CMS has attempted to keep up, offering additional FAQs. Several of the more recent FAQs are of particular interest to …