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IRS Extends ACA Reporting Deadline and Transitional Relief in 2020

  • Updated December 3, 2018
Click here to read online On Thursday, the IRS issued Notice 2018-94, which will extend the information-reporting due dates under section 6055 and 6056 from January 31, 2019, to March 4, 2019. The announcement comes after continued advocacy from NAHU requesting a delayed due date for reporting. The extension grants additional time for insurers, self-insuring […]
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Legislative Brief: Controlled Group and Affiliated Service Group Rules

  • Updated July 8, 2015
Click here to download a printable version with diagrams and charts. The Internal Revenue Code (Code) contains controlled group rules and affiliated service group rules that are used to determine if two or more employers must be grouped together and treated as a single employer for certain purposes. To determine their compliance with employee benefit laws, […]
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Final Forms Released for Individual and Employer Mandate Reporting

  • Updated July 8, 2015
February 18, 2015 Click here to download a printable pdf Recently, the Internal Revenue Service released final forms and instructions for reporting on the individual mandate (Code Sec. 6055) and the employer mandate  (Code Sec. 6056). While these final forms (1094-C and 1095-C) reference calendar year 2014, reporting for 2014 is not required. Employers will be […]
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Relief for Small Employers Reimbursing Individual Policies

  • Updated July 8, 2015
March 19, 2015 Click here to download a printable pdf An employer cannot offer employees cash to reimburse the purchase of an individual policy, whether or not the employer treats the money as pre-tax or post-tax to the employee. Such arrangements (called “employer payment plans”) are subject to the market reform provisions of the Affordable Care […]
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Guidance Issued Regarding Supplemental Excepted Benefits

  • Updated July 8, 2015
March 18, 2015 Click here to download a printable pdf The Departments of Labor (“DOL”), Health and Human Services (“HHS”), and the Treasury (collectively, the “Departments”) have become aware of health insurance carriers selling supplemental products that provide a single benefit. At least one carrier is characterizing this type of coverage as an excepted benefit. These […]
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2016 Cost-Sharing Limits, Reinsurance Fee, and Other Changes Related to the Exchange

  • Updated July 8, 2015
April 9, 2015 Click here to download a printable pdf On February 27, 2015, the Department of Health and Human Services (“HHS”) changed cost-sharing and transitional reinsurance program fee limits and released standards for health insurers and the Exchange (a.k.a. the Health Insurance Marketplace). This article identifies a few items of note for employers. 2016 Cost-sharing […]
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Cadillac Tax: Preliminary Guidance, Part 1

  • Updated July 8, 2015
April 16, 2015 Click here to download a printable pdf The IRS issued preliminary guidance regarding the excise tax on high cost employer-sponsored health coverage, commonly known as the “Cadillac Tax.” Notice 2015-16 describes potential approaches being considered in developing guidance under Section 4980l.  Specifically the Notice addresses (1) the definition of applicable coverage, (2) the […]
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Employer Reporting Guide for Large Employers 6055 and 6056

  • Updated July 8, 2015
April 23, 2015 This Guide includes: Overview of Employer Responsibilities – what to complete and when, Background – No Coverage vs. Offer Coverage Penalties, What Information To Collect – and reported monthly, Form 1094-C with employer-level data, Form 1095-C with employee level data, Filing and Distributing the Forms – deadlines, penalties for non-compliance. Click here […]
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Cadillac Tax Preliminary Guidance: Part 2

  • Updated July 7, 2015
May 19, 2015 Click here to download a printable pdf The IRS issued Notice 2015-16 to begin the process of developing regulatory guidance regarding the excise tax on high cost employer-sponsored health coverage, commonly known as the “Cadillac Tax.” Beginning January 1, 2018, a 40% excise tax will apply on the cost of applicable coverage […]
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