Certain Events Trigger 30 or 60-Day Special Enrollment Periods Under HIPAA, certain events that happen to employees or their dependents trigger a right to “special enroll” in a group health plan. Special enrollment allows individuals who previously declined health coverage to enroll in coverage outside of a plan’s open enrollment period. An employee and his…
Online Form for Employers Offering Prescription Drug Coverage to Medicare Part D-Eligible Individuals The Medicare Modernization Act requires employers that provide prescription drug coverage to Medicare-eligible individuals to complete the Online Disclosure Form to the U.S. Centers for Medicare & Medicaid Services (CMS) to report whether such coverage is creditable prescription drug coverage. Creditable coverage…
The Internal Revenue Service has announced that the 2018 annual limitation on health savings account (HSA) contributions by individuals with family coverage under a high deductible health plan (HDHP) is now $6,850. This limit was previously announced as $6,900, but has been revised downward due to an inflation adjustment provision in the Tax Cuts and…
The Internal Revenue Service has updated its Q&As regarding Form 1094-C and 1095-C information reporting by applicable large employers (ALEs)—generally those with at least 50 full-time employees, including full-time equivalent employees, in the preceding calendar year. The Q&As answer the following questions and more: For which employees must an ALE file Form 1095-C? What information…
Certain Employers Required to Electronically File Returns Employers subject to the Affordable Care Act’s (ACA) information reporting requirements are reminded that the deadlines to file and furnish Forms 1094 and 1095 are quickly approaching. The reporting deadlines in 2018 are for reporting information on the 2017 calendar year, and are as follows: Applicable large employers…
Rule Would Permit Associations Based on Industry or Geography The U.S. Department of Labor (DOL) has issued a proposed rule which would allow employers to join together as a single group to offer group health insurance coverage to current employees, former employees, working owners, and their family members as part of an “association health plan.”…
Requirement is Effectively Repealed Beginning in 2019 Individuals are reminded that the section of the Tax Cuts and Jobs Act which effectively repealed the individual shared responsibility provision (“individual mandate”) of the Affordable Care Act does not become effective until 2019. As a result, individuals are required to have minimum essential health coverage, qualify for…
Percentage Down from 2017 Under the employer shared responsibility (“pay or play”) provisions of the Affordable Care Act, applicable large employers—generally those who had 50 or more full-time employees (including full-time equivalent employees) in 2017—may be subject to a penalty if they do not offer affordable coverage that provides minimum value to their full-time employees…
Tax Previously Set to Become Effective in 2020 President Trump has signed the Extension of Continuing Appropriations Act, which (among other things) delays implementation of the “Cadillac Tax,” the Affordable Care Act’s excise tax on high-cost employer-sponsored health coverage, until 2022. Previously, this tax—which would impose a 40% tax on plans that cost more than…
Definitions Essential to Understanding ‘Pay or Play’ Compliance In general, under the employer shared responsibility (“pay or play”) provisions of the Affordable Care Act (ACA), applicable large employers—generally those with 50 or more full-time employees, including full-time equivalent employees—may be subject to a penalty if they do not offer minimum essential coverage that is affordable…
