Follow us on:

facebook_med.pnglinkedin_med.png

Ask an Expert at GCG

August, 2014

Draft Instructions for Employer Reporting of Health Coverage Released

The Affordable Care Act (ACA) created new  reporting requirements under Internal  Revenue Code (Code) Sections 6055 and  6056. Under these new reporting rules,  certain employers must provide information  to the IRS about the health plan coverage  they offer (or do not offer) to their  employees.   Read More

June, 2014

Supreme Court Rejects Contraceptive Mandate for Some Companies

On June 30, 2014, the U.S. Supreme Court issued its ruling in two related cases challenging the Affordable Care Act’s (ACA) contraceptive coverage mandate. In these cases, three closely held for-profit corporations—Hobby Lobby Stores, Mardel and Conestoga Wood Specialties—argued that they should not be required to comply with the contraceptive mandate because covering certain types of contraceptives under their health plans violates their sincere religious beliefs.  Read More

May, 2014

Heatlthcare Reform: New Guidance on COBRA and ACA Marketplace Coverage: The Gap in Coverage is (Not Quite) Filled

On January 9, 2014, the Departments of Health and Human Services (HHS), Labor and Treasury issued There has been much confusion and concern about the interplay between the COBRA continuation coverage rules and the new Health Insurance Marketplace established under the Affordable Care Act (the "Marketplace"). One important question has been how individuals could transition from COBRA continuation coverage to (often cheaper) Marketplace coverage. Also, many individuals are confused about whether they should continue their available COBRA continuation coverage or separately opt for coverage through the Marketplace. To help clarify the rules, the government agencies have issued some important new guidance. Read More

March, 2014

Affordable Care Act Countdown: New Guidance for Individual Health Insurance

Those without individual health insurance only have 18 days (untill March 31, 2014) to purchase coverage. Only qualifying events will allow individuals to purchase insurance after the March 31st deadline. Read More

February, 2014

Health Care Reform: Final Employer Shared Responsibility Regulations Issued

Applicable large employers that have fewer than 100 fulltime employees will have an additional year, until 2016, to comply with the pay or play rules. The Affordable Care Act (ACA) imposes a penalty on large employers that do not offer minimum essential coverage to fulltime employees and their dependents. Large employers that offer this coverage may still be liable for a penalty if thecoverage is unaffordable or does not provideminimum value. The ACA’s employer mandate provision is often referred to asthe “employer shared responsibility” or “payor play” rules. On Feb. 10, 2014, the U.S. Treasury Department released final regulations implementing the employer sharedresponsibility provisions of the ACA. Read More

January, 2014

Health Care Reform: Affordable Care Act Implementation FAQs

On January 9, 2014, the Departments of Health and Human Services (HHS), Labor and Treasury issued FAQs to clarify Patient Protection and Affordable Care Act (PPACA) provisions related to several topics including: Preventive Services, Cost-sharing Requirements, Expatriate Health Plans,  Wellness Programs, Fixed Indemnity Insurance and  Mental Health Parity 

We have summarized the information in the FAQs and provided a link to the complete FAQs. Read More

December, 2013

Health Care Reform: Paying Premiums for Individual Health Insurance Policies

Starting in 2014, the Affordable Care Act (ACA) may make purchasing health insurance in the individual market more accessible for individuals. Due to the ACA’s reforms and the rising costs of health coverage, some employers have considered whether they should help employees pay for individual health insurance policies instead of offering an employer-sponsored group health plan.

On Sept. 13, 2013, the Internal Revenue Service (IRS) issued Notice 2013-54 (Notice) to address how certain ACA reforms apply to health reimbursement arrangements (HRAs), cafeteria plans and other employer payment plans. The Notice is effective for plan years beginning on or after Jan. 1, 2014.The Notice discourages employers from helping employees pay for individual policies in lieu of offering a group health plan by eliminating the tax savings associated with contributions toward individual coverage  Read More

November, 2013

Health Care Reform: White House Announces Transition Policy For Canceled Health Plans

Responding to pressure from consumers andCongress, on Nov. 14, 2013, President Obamaannounced a new transition policy for 2014. Under the new policy, individuals andsmall businesses whose coverage has beencanceled (or would be canceled) because itdoes not meet the ACA’s standards may beable to re-enroll or stay on their coverage foran additional year. Read More

October, 2013

Health Care Reform: Changed to the Use-or-Lose Rule for Health FSAs

On Oct. 31, 2013, the Internal RevenueService (IRS) released Notice 2013-71(Notice), which relaxes the “use-or-lose”rule for health FSAs. Under the relaxedrule, employers will now be able to allowparticipants to carry over up to $500 inunused funds into the next year. This modification applies only if the plandoes not also incorporate the graceperiod rule. Read More

September, 2013

Exchange Notice Requirement: FAQs on Implementation

The Patient Protection and Affordable Care Act (PPACA) requires all employers subject to the Fair Labor Standards Act (FLSA) to provide notices to current employees and new hires about the forthcoming health insurance exchanges and subsidies that may be available through the exchanges for qualified individuals. In January of 2013, the federal Department of Labor (DOL) issued guidance delaying the notice requirement under Section 1512 of the law to better coordinate it with the open enrollment period for the new health insurance exchange marketplaces. In May of 2013, further guidance was issued indicating that employers are to provide these notices to employees by October 1, 2013. This frequently asked question (FAQ) document is intended to assist you with the implementation the notice requirement.  Read More

July, 2013

Health Care Reform: Employer Mandate Penalties Delayed Until 2015

The Obama Administration has postponed the Affordable Care Act (ACA) employer mandate penalties for one year, until 2015. The Department of the Treasury announced the delay on July 2, 2013, along with a similar delay for information reporting by employers, health insurance issuers and self-funded plan sponsors. The delay does not affect any other provision of the ACA, including individuals’ access to premium tax credits forcoverage through an Exchange. The Treasury plans to issue more formal information about the delay within a week. Read More

June, 2013

Health Care Reform: Health Insurance Exchanges - Employer Coverage Tool

The Affordable Care Act (ACA) calls for the creation of state-based competitive marketplaces, known as Affordable Health Insurance Exchanges (Exchanges), for individuals and small businesses to purchase private health insurance. ACA requires the Exchanges to become operational in 2014. According to the Department of Health and Human Services (HHS), the Exchanges will allow for direct comparisons of private health insurance options based on price, quality and other factors, and will coordinate eligibility for premium tax credits and other affordability programs. Read More

May, 2013

Health Care Reform: Proposed Rule Released on Minimum Value and Affordability 

On May 3, 2013, the Internal Revenue Service (IRS) released a proposed rule on the minimum value and affordability rules under the Affordable Care Act (ACA). In this proposed rule, the IRS provides guidance on determining whether health coverage under an employer-sponsored plan is affordable and provides minimum value for purposes of determining the employer “pay or play” penalties. In particular, the proposed regulation: Read More

 

DOL Issues Model Exchange Notice and Sets Compliance Deadline

On May 8, 2013, the Department of Labor (DOL) released Technical Release 2013-02 to provide temporary guidance on the Exchange notice requirement. This temporary guidance will remain in effect until the DOL issues regulations or other guidance. According to the DOL, future regulations or other guidance will provide employers with adequate time to comply with any additional or modified requirements.   Read More

Transition Policy for Canceled Health Plans

The Affordable Care Act (ACA) includes several key reforms that create new coverage standards for health insurance policies, beginning in 2014. Late in 2013, millions of Americans received notices informing them that their plans would be canceled because they did not comply with the ACA’s reforms. President Obama received criticism that these cancelations went against his assurances that if consumers had a plan that they liked, they could keep it.

Responding to pressure from consumers and Congress, on Nov. 14, 2013, President Obama announced a transition relief policy for 2014 for non-grandfathered coverage in the small group and individual health insurance markets. If permitted by their states, the transition policy gives health insurance issuers the option of renewing current policies for current enrollees without adopting all of the ACA’s market reforms for 2014.

Tobacco Use Surcharge in 2014

Effective for 2014, the Affordable Care Act (ACA) allows health insurance issuers in the individual and small group markets to impose a tobacco use surcharge, within a ratio of 1.5 to 1. This means that, beginning in 2014, health insurance issuers in the individual and small group markets may vary insurance premiums based on a policyholder (or dependent’s) tobacco use, up to 1.5 times the regular premium. In addition, issuers of qualified health plans (QHPs) offered through an Exchange may also impose up to a 1.5:1 tobacco use surcharge.

 

April, 2013

Health Care Reform: Proposed Rule On Exchange Navigator Programs

The Affordable Care Act (ACA) calls for the creation of state-based competitive marketplaces, known as Affordable Health Insurance Exchanges (Exchanges), for individuals and small businesses to purchase private health insurance. The ACA requires the Exchanges to become operational in 2014, with enrollment beginning Oct. 1, 2013.To help consumers use the Exchanges and review insurance options, the ACA requires each Exchange to establish a Navigator program.  Read More

Health Plan Certification for HIPAA Compliance 

The Affordable Care Act (ACA) requires health plans to certify to the Department of Health and Human Services (HHS) that their data and information systems comply with HIPAA’s electronic transaction standards and operating rules. The ACA specified an initial certification deadline of Dec. 31, 2013, for the following transactions:

  • Eligibility for a health plan;
  • Health care claim status; and
  • Health care electronic funds transfer (EFT) and remittance advice.

Annual Deductible Limit Repealed for Small Health Plans

On April 1, 2014, President Obama signed the Protecting Access to Medicare Act of 2014 (Act) into law. The Act’s main provisions preserve the pay rate for physicians treating Medicare patients and delay the compliance deadline for converting to the updated International Classification of Diseases codes for at least one year.

The Act also eliminates the Affordable Care Act’s (ACA) annual deductible limit that applied to health plans in the small group market. This change is retroactively effective to when the ACA was enacted in March 2010.

 

March, 2013

Health Care Reform: Proposed guidance issued on 90 day waiting period

For plan years beginning on or after Jan. 1, 2014, the Affordable Care Act (ACA) prohibits group health plans and group health insurance issuers from applying any waiting period that exceeds 90 days. ACA’s 90-day waiting period limit applies to both non-grandfathered and grandfathered group health plans and health insurance coverage. Read More

New Options for Individuals Whose Policies Have Been Cancelled

Late in 2013, millions of Americans received notices informing them that their health insurance plans were being cancelled because they do not comply with the reforms of the Affordable Care Act (ACA) that will take effect in 2014. These reforms include a prohibition on annual limits and requirements that individual and small group policies cover a comprehensive set of benefits.

On Nov. 14, 2013, President Obama announced a transition policy that would enable insurers to renew existing plans and policies that do not comply with the ACA. However, many states are choosing not to adopt the transition policy, and many individuals were finding other coverage options to be more expensive than their cancelled plans or policies.

Transition_Policies_for_Canceled_Health_Plans

If you have received a notice that your health insurance plan is canceled, you are probably wondering what to do next. With so many changes occurring due to health care reform, you need to know how to obtain health coverage. Read on for information about why policies are being canceled and what new options are available if you have a canceled policy.

Final Employer Shared Responsibility Regulations Issued

The Affordable Care Act (ACA) imposes a penalty on applicable large employers (ALEs) that do not offer minimum essential coverage to full-time employees and their dependents. ALEs that offer this coverage may still be liable for a penalty if the coverage is unaffordable or does not provide minimum value. The ACA’s employer mandate provision is often referred to as the “employer shared responsibility” or “pay or play” rules.

Plans Subject to the Affordable Care Act

The health care reform law, known as the Affordable Care Act (ACA), makes significant changes to the U.S. health care system, including new coverage requirements, patient protections and cost limitations. These changes generally apply to group health plans and health insurance issuers, but not to certain “excepted benefits.”

Exchange Subsidy Availability Expanded in 2014 Due to Technical Difficulties

Beginning in 2014, the Affordable Care Act (ACA) makes health insurance subsidies available through the Exchanges, in the form of premium tax credits and cost-sharing reductions, to help eligible individuals purchase health insurance through an Exchange. By reducing a taxpayer’s out-of-pocket costs, the subsidies are designed to make coverage through an Exchange more affordable.

On Feb. 27, 2014, the Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) issued guidance expanding the availability of these Exchange subsidies in 2014. If certain conditions are met, this guidance makes subsidies available for individuals who were unable to enroll in a qualified health plan (QHP) through the Exchange due to technical difficulties with Exchange functions.

Final Rules Released on Reporting for Issuers and Self-funded Employers

The Affordable Care Act (ACA) requires health insurance issuers, self-insured health plan sponsors, government agencies that administer government-sponsored health insurance programs and any other entity that provides minimum essential coverage (MEC) to report information on that coverage to the IRS and covered individuals. This requirement is found in Internal Revenue Code section 6055.

HHS Issues Notice of Benefit and Payment Parameters for 2015 Final Rule

On March 5, 2014, the Department of Health and Human Services (HHS) released its 2015 Notice of Benefit and Payment Parameters Final Rule. The final rule describes payment parameters applicable to the 2015 benefit year and standards relating to the:

  • Premium stabilization programs;
  • Open enrollment period for 2015; and
  • Annual limitations on cost-sharing.

Determining a Health Plan’s “Plan Year” 

Employer-sponsored health plans are subject to a variety of compliance requirements, including those included in the Affordable Care Act (ACA). Many of these requirements are linked to a health plan’s “plan year.”

Examples

 

  • The ACA’s prohibition on pre-existing condition exclusions for all enrollees is effective for plan years beginning on or after Jan. 1, 2014.
  • Health plan sponsors that provide prescription drug coverage to Medicare Part D eligible individuals must provide a disclosure notice to the Centers for Medicare & Medicaid Services (CMS) on an annual basis, within 60 days after the beginning of the plan year.
  • If a health plan is required to file a Form 5500, the deadline (without extensions) is the last day of the seventh month following the end of the plan year.

Supreme Court Hears Religious Challenge to Contraceptive Coverage Mandate

On March 25, 2014, the U.S. Supreme Court heard arguments in two related cases challenging the Affordable Care Act’s (ACA) contraceptive coverage mandate. In these cases, two privately held for-profit companies—Hobby Lobby Stores, Inc. and Conestoga Wood Specialties Corp.—argue that they should not be required to comply with the contraceptive coverage mandate because covering certain types of contraceptives under their health plans violates their religious beliefs.

Premium Tax Credit Eligibility for Victims of Domestic Abuse

The Affordable Care Act (ACA) provides premium tax credits to certain low-income individuals who purchase a qualified health plan (QHP) through an Exchange. These tax credits are intended to help pay for the cost of the QHP coverage.

On March 27, 2014, the Internal Revenue Service (IRS) released Notice 2014-23 (Notice), addressing premium tax credit eligibility for victims of domestic abuse. The Notice provides a transition rule for 2014, allowing a married domestic abuse victim who is unable to file a joint tax return to claim a premium tax credit for Exchange coverage. Under this transition rule, a married individual who is living apart from his or her spouse, and who is unable to file a joint return as a result of domestic abuse, may claim a premium tax credit for 2014 while filing a tax return with a filing status of married filing separately.

 

 

 

February, 2013

Health Care Reform: Pay or Play Penalty Identifying Full Time Employees

Effective Jan. 1, 2014, the Affordable Care Act (ACA) imposes a penalty on large employers that do not offer minimum essential coverage to “substantially all” full-time employees and dependents. Large employers that do offer coverage may still be liable for a penalty if the coverage is unaffordable or does not provide minimum value. Read More

New Health Insurance Marketplace Coverage Options and Your Health Coverage

 When key parts of the health care law take effect in 2014, there will be a new way to buy health insurance:  the Health Insurance Marketplace.  To assist you as you evaluate options for you and your family, this notice provides some basic information about the new Marketplace.

New Health Insurance Marketplace Coverage Options and Your Health Coverage

When key parts of the health care law take effect in 2014, there will be a new way to buy health insurance: the Health Insurance Marketplace. To assist you as you evaluate options for you and your family, this notice provides some basic information about the new Marketplace and employment­based health coverage offered by your employer

New Employer Mandate Transition Relief for 2015

The Affordable Care Act (ACA) imposes a penalty on applicable large employers that do not offer affordable, minimum value coverage to full-time employees and their dependents. These penalties are often referred to as the “employer shared responsibility” or “pay or play” penalties.

On Feb. 10, 2014, the U.S. Treasury Department released final regulations implementing the employer shared responsibility provisions of the ACA.

Employer Mandate Transition Relief Extended for 2015

The Affordable Care Act (ACA) imposes a penalty on applicable large employers (ALEs) that do not offer affordable, minimum value coverage to full-time employees and their dependents. These penalties are often referred to as the “employer shared responsibility” or “pay or play” penalties.

Pay or Play Penalty—Hours of Service Rules Clarified

The Affordable Care Act (ACA) requires large employers to offer affordable, minimum value health coverage to their full-time employees or pay a penalty. This penalty is known as the shared responsibility or pay or play penalty.

On Feb. 12, 2014, the IRS published final regulations on the ACA’s employer shared responsibility rules. The final regulations clarify the definition of “hours of service” for purposes of the pay or play rules.

Employer Mandate Delayed Until 2016 for Medium-sized Employers

The Affordable Care Act (ACA) imposes a penalty on applicable large employers (ALEs) that do not offer minimum essential coverage to full-time employees and their dependents. ALEs that offer coverage may still be liable for a penalty if the coverage is unaffordable or does not provide minimum value. This provision is often referred to as the “employer shared responsibility” or “pay or play” rules.

Final Regulations Released on the 90-day Waiting Period Limit

 

 

January, 2013

Health Care Reform: Exchange Notice Requirements Delayed

The Affordable Care Act (ACA) requires employers to provide all new hires and current employees with a written notice about ACA’s health insurance exchanges (Exchanges), effective March 1, 2013.

On Jan. 24, 2013, the Department of Labor (DOL) announced that employers will not be held to the
March 1, 2013, deadline. They will not have to comply until final regulations are issued and a final
effective date is specified. Read More

Health Care Reform: Employer Penalties - Affordability Safe Harbors

Beginning in 2014, the Affordable Care Act (ACA) imposes “pay or play” requirements on large employers. Under these “pay or play” requirements, large employers that do not offer health coverage to their full-time employees and their dependents, or that offer coverage that is either unaffordable or does not provide minimum value, may be subject to a penalty. This penalty is also referred to as a “shared responsibility payment.”

On Jan. 2, 2013, the Internal Revenue Service (IRS) published proposed regulations that provide further guidance on whether coverage will be considered affordable. The IRS previously announced the Form W-2 safe harbor, which allows employers to assess affordability for each employee according to the employee’s Form W-2 wages only (rather than household income). The proposed regulations: Read More

Employer Mandate Transition Relief Extended for 2015

The Affordable Care Act (ACA) imposes a penalty on applicable large employers (ALEs) that do not offer affordable, minimum value coverage to full-time employees and their dependents. These penalties are often referred to as the “employer shared responsibility” or “pay or play” penalties.

On Feb. 10, 2014, the U.S. Treasury Department released final regulations implementing the employer shared responsibility provisions of the ACA. Under the final regulations, a package of limited transition rules provided for 2014 in the proposed regulations is extended to 2015. The final regulations also include a number of new transition rules for employers.

 

Do you have a Healthcare Reform Question?

Health Care Reform: IRS Q&As on Form W-2 Reporting

Executive Summary

The Patient Protection and Affordable Care Act (PPACA) added Internal Revenue Code (Code) section 6051(a)(14),which requires employers to report the aggregate cost of employer-sponsored group health plan coverage on theiremployees' Forms W-2. This requirement was originally effective for the 2011 tax year and the W-2 Forms thatwould be provided in January 2012. However, the IRS later made reporting optional for 2011. Read more.


Full Name *
Email *
Company Name:
Are you a GCG Client: *
 Yes
 No
Please enter your question *
 

The information on our website is only a summary of the law. It is intended for general information purposes only and is not legal advice. We do not guarantee or warrant accuracy of the content above as it does not contain complete statements of the law. Always contact an attorney to get complete, accurate and up-to-date legal advice.