On July 24, 2014, the Internal Revenue Service (IRS) released three Revenue Procedures (2014-46, 2014-37, and 2014-41), which provide guidance to individuals on their obligation to maintain minimum essential coverage (MEC) under the Affordable Care Act’s (ACA) so-called “individual mandate.”
Most notably for employers is that, in Revenue Procedure 2014-37, the IRS increased the threshold
For the second time in two years the United States Supreme Court (the “Court”) has ruled against the Obama Administration with respect to elements of the Affordable Care Act (the “ACA”). In a 5-4 decision announced today in Burwell v. Hobby Lobby Stores, Inc. (“Hobby Lobby”) (f/k/a Sebelius v. Hobby Lobby Stores, Inc.), the Court ruled that the federal government, acting through Health and Human Services (“HHS”), overstepped its bounds by requiring faith-based private, for-profit employers to pay for certain forms of birth control that those employers argued contradicted their religious beliefs, in violation of the Religious Freedom Restoration Act of 1993 (“RFRA”).
In Hobby Lobby, the Court found that for-profit employers are “persons” for purposes of the RFRA. The Court, assuming that the government could show a compelling interest in its desire to provide women with access to birth control, ultimately held that the government could have met this interest in a less burdensome way.
On June 20, the Federal regulatory agencies in charge of health care reform guidance (the Departments of Labor, Treasury, and Health and Human Services) released final regulations (“Final Regulations”) clarifying the relationship between a group health plan’s eligibility criteria and the Affordable Care Act’s (ACA) 90-day limit on waiting periods. Specifically, the Final Regulations (published
In April, the IRS released the 2015 inflation adjustments for Health Savings Accounts (HSA) and HSA-qualified high deductible health plans (HDHPs). A month earlier, HHS released details on the “premium adjustment percentage,” which is used to calculate annual increases in cost sharing under the Affordable Care Act’s (ACA) maximum out-of-pocket rules. These ACA rules limit participant cost-sharing under non-grandfathered group health plans for covered, in-network essential health benefits.
For plan years beginning in 2014, the ACA’s maximum out-of-pocket limits were tied to the out-of-pocket limits established for HDHPs. That caused some to assume that the ACA maximum out-of-pocket limits and the HDHP limit would always be the same. But they aren’t. Under the ACA, HHS is required to use a different methodology for calculating any annual adjustments than the IRS uses for HDHPs. Therefore, starting in 2015, the two limits will begin to differ as shown in the first table below. The second table contains other inflation adjustments for HSAs and HDHPs. In both tables, figures are shown single/family.