Recent Posts
Tuesday, March 24, 2015

In a rule published on March 19, 2015, the Department of Labor (“DOL”) indicated that a year can last 14 months, at least when it comes to the disclosure of fees, expenses and other investment-related information by participant-directed individual account […]

Monday, March 16, 2015

Welcome back to the third and final segment of our 3-part discussion of the ACA reporting and disclosure forms. In Part 1, we focused on the basics: identifying the various forms, the reporting entities (focusing on employer as filers), and […]

Thursday, March 12, 2015

Welcome back to Part 2 in our 3-part discussion of the ACA reporting and disclosure forms. In Part 1, we focused on the basics: identifying the various forms, the reporting entities (focusing on employer as filers), and deadlines for filing. […]

Tuesday, March 10, 2015

The unexpected occurred in 2013 when implementation of the Employer Mandate was delayed due to the inability of the IRS to timely issue the requisite reporting and information forms. Now that those forms have finally been issued, we can readily […]

Thursday, March 5, 2015

In proposed regulations published in the Federal Register on November 26, 2014, the Department of Health and Human Services (HHS) proposed limits on annual out-of-pocket maximums for 2016. In one paragraph of the preamble, HHS proposed to “clarify” that the […]

Tuesday, February 24, 2015

Employer payment plans, which include arrangements where an employer pays, or reimburses an employee, for some or all of the premium expenses incurred for an individual health insurance policy, violate market reforms under the Affordable Care Act (“ACA”). Notice 2015-17 […]

Friday, February 13, 2015

Time flies when you’re having fun… or something like that?! Next month will mark the fifth year anniversary of the enactment of the Patient Protection and Affordable Care Act (as amended by the Health Care and Education Reconciliation Act). This […]

Thursday, February 12, 2015

The facts surrounding the Anthem breach continue to evolve as does Anthem’s handling of the situation. Based on the current status of the investigation, and Anthem’s current reactions to the incident, there are steps which group health plan sponsors should […]

Wednesday, February 11, 2015

If your 2015 New Year’s Resolution was to fully comply with all aspects of California’s New Paid Sick Leave Law, you may already be in trouble. Although the substantive portions of the law do not kick in until July 1, […]

Tuesday, February 10, 2015

In prior posts, we have described how coverage has to be “affordable” to avoid the ACA play or pay penalty. We’ve usually used the shorthand that the premium must be no more than 9.5% of an employee’s household income. However, […]