Employee Benefits & Executive Compensation Blog

The View from Proskauer on Developments in the World of Employee Benefits, Executive Compensation & ERISA Litigation

Tag Archives: Damian A. Myers

IRS Notice 2015-87 (Part 1) – IRS Issues New HRA Integration Rules

On December 16, 2015, the Internal Revenue Service issued Notice 2015-87 containing guidance on a wide-range of topics under the Affordable Care Act (ACA). In addition to providing guidance on affordability and COBRA matters (which will be described in subsequent blogs), Notice 2015-87 builds upon prior guidance to regulate further the use of health reimbursement … Continue Reading

IRS Notice 2015-86 — The Limited Effect of Obergefell

Last week, the Internal Revenue Service (IRS) issued Notice 2015-86, providing guidance on the application of the U.S. Supreme Court’s decision in Obergefell v. Hodges to qualified retirement plans and health and welfare plans, including cafeteria plans.  Importantly, and as expected, the IRS comments in the Notice that it does not anticipate that Obergefell will … Continue Reading

So-Called Cadillac Tax Delayed until 2020

On December 16, 2015, the House of Representatives struck a tentative deal on an appropriations bill that would fund the federal government through the 2016 fiscal year.  Among other things, the 2016 Consolidated Appropriations Bill would delay the effective date of the controversial 40% excise tax on high-cost health plans (commonly referred to as the … Continue Reading

New Affordable Care Act FAQs Provide Guidance on Preventive Services, Wellness Programs and Mental Health Parity

On October 23, 2015, the Departments of Labor, Health and Human Services and Treasury (the “Agencies”) jointly released their twenty-ninth (XXIX) set of Frequently Asked Questions (FAQs) about Affordable Care Act (ACA) implementation.  This latest set of FAQs generally (1) clarify that certain services performed ancillary to various preventive services must also be covered without … Continue Reading

ACA Automatic Enrollment Mandate Repealed by Bipartisan Budget Act

On Monday, November 2nd, the President signed the Bipartisan Budget Act of 2015 (BBA).  Some legislators had hoped that a budget deal would at least include a repeal of the controversial 40% excise tax on high-cost health care (the so-called “Cadillac Tax”).  However, the BBA left the Affordable Care Act (ACA) largely intact, with the … Continue Reading
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