On Monday, February 10, 2014, the IRS released final regulations on the Affordable Care Act’s (ACA) employer “shared responsibility” provisions, also known as the “pay-or-play” mandate. The final regulations weigh in at 227 pages. We will review them over the coming days and will release additional communication pieces once we fully digest these new regulations. … Continue Reading
The Supreme Court will review two of the numerous lawsuits challenging the Affordable Care Act’s (ACA) requirement that group health plans and insurers cover, without cost-sharing, contraceptives and/or abortifacients (the “Contraceptive Mandate”). The plaintiffs in these suits are secular, for-profit corporations and their owners, and they assert that being forced to comply with the Contraceptive … Continue Reading
A federal court in New York appears to have issued the first published decision addressing alleged violations of the enhanced benefit claim procedures arising out of the Affordable Care Act (ACA). The new procedures contain various participant-friendly provisions, such as the right to external review, that alter ERISA’s existing benefit claim procedures for non-grandfathered welfare … Continue Reading
On May 3, 2013, the IRS released proposed regulations on certain provisions relating to the federal premium tax credits that eligible individuals will use to purchase subsidized health insurance coverage from public exchanges starting in 2014.… Continue Reading
On April 23rd, the DOL, HHS and IRS (the “Agencies”) released an updated template for the Summary of Benefits and Coverage (“SBC”) that group health plans and issuers are required to send to plan participants. This updated SBC is the template to be used by plan sponsors and issuers to comply with the SBC requirements … Continue Reading
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