I have blogged more on the topic of how the Health Care Reform Act applies to employers that reimburse employers for individual health insurance policies than any other topic in the last year. At one point in time, as indicated in my post of June 11, 2014, The IRS Meant What It Said in Notice […]
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2015 is a significant year for health care reform because the large employer shared responsibility penalties under Internal Revenue Code Section 4980H take effect for most large employers. See our SW Benefits Update, “Health Care Reform’s Employer Shared Responsibility Penalties: A Checklist for Employers,” for a detailed explanation of the large employer penalties. Many people are under […]
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As we move into 2015, employers continue to grapple with numerous Health Care Reform concepts. Employers should be cautious regarding arrangements promoted to avoid health care penalties because the agencies are cracking down, as shown below. On November 4, 2014, the IRS and other agencies indicated that they have become aware that group health plans […]
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On September 18, 2014, the IRS released IRS Notice 2014-55, which now allows employees to make certain mid-year health coverage changes when they reduce below 30 hours of service or enroll in a qualified health plan through a Marketplace. Employers who want to permit either of these two new changes (which are explained in detail […]
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In our 2013 End of Year Plan Sponsor “To Do” List Part 2 – Health and Welfare I did a lengthy summary of the various changes required to employer health care arrangements on account of IRS Notice 2013-54. On May 6, 2014, I followed that up with a blog entitled Non-integrated health reimbursement arrangements (whatever […]
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I gave a presentation last week at the Western Pension & Benefits Conference Phoenix Chapter Spring Conference entitled “Ding Dong DOMA’s Dead – The Supreme Court’s Same-Sex Marriage Ruling and Its Impact on Employee Benefit Plans.” Upon finishing my presentation, I realized my last few slides are a good checklist. On April 4th, the IRS […]
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As explained in my Checklist for Employers, a large employer will have to pay a subsection (a) penalty for any month if it does not offer “minimum essential coverage” (“MEC”) to substantially all (i.e., 70% for 2015 and 95% for future years) of its full-time employees and their dependents if one or more full-time employees […]
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Most employee benefit plans are subject to nondiscrimination rules. In order to prevent employers from breaking apart companies in order to avoid these nondiscrimination rules, most employee benefit plans, in performing nondiscrimination testing, must take into account related businesses (i.e., controlled groups and affiliated service groups). I’ve been blogging recently about the large employer shared […]
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Last fall the IRS and DOL issued nearly identical guidance, IRS Notice 2013-54 and DOL Technical Release 2013-03, explaining how certain Health Care Reform Act rules apply to health reimbursement arrangements (“HRAs”). Notice 2013-54 is not good news for most HRAs, also called medical expense reimbursement plans (“MERPs”). Executive physical plans are often structured as […]
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Health care reform is confusing. There are so many new terms and concepts. One concept that has been getting a lot of attention lately is MEC. MEC stands for “minimum essential coverage” and is a fancy name for basic health coverage. MEC is important for two main reasons — First, starting in 2014, individuals who don’t […]
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