Tag Archives: Play or Pay/Shared Responsibility/4980H

“King” of the Road

In Roger Miller’s 1964 hit by the above name, he tells the tale of “a man of means by no means,” a man just scraping to get by. While he may not have a phone, a pool, pets, or cigarettes […]

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Individual Mandate Regulations Address Affordability – And Why Employers May Care

Just before Thanksgiving, the IRS issued final regulations on the individual mandate under the Affordable Care Act (“ACA”). The individual mandate requires individuals to maintain health insurance (i.e., “minimum essential coverage”) or pay a penalty. The regulations adopt in part, […]

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Election Day Surprise: Skinny Plans Will Need to Fatten Up

Early this morning, the IRS, in a coordinated effort with the DOL and HHS, issued guidance that basically said that so-called “skinny” plans won’t get employers out of the “play or pay” penalties. Limited grandfathering is available for so called […]

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Check it Out and Check it Off: 2015 Group Health Plan Checklist

With 2015 just around the corner, certain mandates under the Patient Protection and Affordable Care Act, as amended (“ACA”) are about to become effective. Health plans also have several existing enrollment and annual notice requirements. Below is a checklist of […]

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Dealing with Changes to an Employee’s Measurement Period

Recently the IRS issued Notice 2014-49, offering guidance for situations in which the measurement period or method applicable to an employee changes. Background Under the Affordable Care Act, as amended (“ACA”) an applicable large employer risks the imposition of a […]

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Kind of Halbig Deal

You may have heard about the potentially crippling blow to ACA (as some have described) dealt by a three-judge panel of the D.C. Circuit Court of Appeals today in Halbig v. Burwell.  Basically, a group of individuals and employers challenged […]

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Speaker Boehner’s Lawsuit and the ACA

Unless you’ve been hiking Mount Kilimanjaro for the last month, you’ve no doubt heard about Speaker Boehner’s proposed lawsuit against the President.  The Speaker, and apparently many House Republicans, are upset that the President has not, in their view, upheld […]

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ACA Employer Mandate / Reporting and Tracking Hours

As if compliance with the ACA’s market reforms and complex plan design rules (including an assessment of affordability and minimum value), hasn’t caused enough headaches – now you have to prepare to track and report detailed information about your compliant […]

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Mr. Spock, Social Influence, and Eliminating the ACA Employer Mandate

Humans are not logical.  Consider popular Star Trek characters Mr. Spock or Lt. Cmdr. Data (depending on which generation of Star Trek you prefer).  Either by choice or by nature, each was constrained to view the world through the lens […]

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The Monthly Measurement Method: Is There a “There”, There?

The proposed rules for implementation of the Employer Mandate (aka “Shared Responsibility for Employers Regarding Health Coverage” or “Play or Pay“) provided an optional Look-Back Method for identifying which employees are full-time and must be offered health care coverage to […]

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