As efforts to reform the Affordable Care Act (the “ACA”) stall in Congress, a recent government report suggests that the Internal Revenue Service is preparing to identify and collect employer shared responsibility penalties. The Treasury Inspector General for Tax Administration issued the report, Affordable Care Act: Assessment of Efforts to Implement the Employer Shared Responsibility […]
As we previously discussed in our May 19, 2016 SW Benefits Update, the Department of Labor (the “Department”) previously issued final regulations on fiduciary conflicts of interest in retirement programs. The rules, which focus on curbing self-interested advice to retirement plan and IRA participants, were slated to become effective April 10, 2017. However, the Department […]
The IRS delivered welcome news to employers gearing up to meet the Affordable Care Act’s (“ACA”) information reporting deadlines for the 2016 calendar year. In Notice 2016-70, the IRS extended the deadline to furnish Forms 1095-B and 1095-C to employees. The new deadlines are provided below. Old Distribution Deadline New Distribution Deadline Form 1095-B […]
The IRS recently announced cost-of-living adjustments for 2017 in Notice 2016-62. The key dollar limits, along with last year’s limits, are noted below. Maximum Qualified Retirement Plan Dollar Limits 2016 2017 Limit on Section 401(k) deferrals (Section 402(g)) $18,000 $18,000 Dollar limitation for catch-up contributions (Section 414(v)(2)(B)(i)) $6,000 $6,000 Limit on deferrals for government […]
In recent months, we have written a fair amount about providing transgender benefits in light of the nondiscrimination provisions of the Affordable Care Act. Our blogs of March 30, 2016 and June 22, 2016 highlight the key contours of the nondiscrimination rule. In our June 22 post, we mention in passing that the final nondiscrimination […]
On April 6, 2016, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued an updated Summary of Benefits and Coverage (“SBC”) template. The latest template represents an effort by the Departments to enhance consumer access to information regarding their health care options. Although the new template is shorter than the prior […]
On May 18, 2016, the Department of Health and Human Services (“HHS”) issued final regulations implementing the nondiscrimination provisions of the Affordable Care Act. As we discussed in our March 30, 2016 blog, the rule prohibits discrimination on the basis of sex and gender identity in the provision of health programs. In application, the final […]
Assistant Secretary of Labor Phyllis Borzi recently offered informal guidance on the broad scope of nondiscrimination regulations proposed under Section 1557 of the Affordable Care Act. During her remarks at the ABA Labor Section Employee Benefits Committee Meeting in February, Ms. Borzi indicated that the proposed regulations would apply to any health plan that receives […]
The IRS delivered a late Christmas gift December 28, 2015 when, in Notice 2016-4, it extended the Affordable Care Act (“ACA”) reporting deadlines. The new deadlines affect distribution and filing of Forms 1094 and 1095 for calendar year 2015 and are provided below. Section 6055 Health Coverage Reporting Old Filing Deadline New Filing Deadline Form […]
