As part of our ongoing series on the final regulations expanding the availability of health reimbursement accounts (“HRAs”), we discussed the newly-created Individual Coverage HRAs, which generally allow for employers to reimburse employees’ premiums for health coverage purchased on the individual market. As noted in the final regulations, the new Individual Coverage HRA is a … Continue Reading
As discussed in our June 18th blog entry, the Departments of Labor, Health and Human Services, and Treasury (collectively, the “Departments”) recently released final regulations expanding the use of health reimbursement arrangements (“HRAs”). Among the more important aspects of the final regulations was the reversal of long-standing Affordable Care Act (“ACA”) policy that HRAs or … Continue Reading
On June 13, 2019, the Department of Labor, together with the Department of Health and Human Services and the Department of the Treasury (collectively, the “Departments”), published final regulations designed to expand the use of health reimbursement arrangements (“HRAs”). The final regulations provide, in general, that HRAs may be used to (1) reimburse premiums for … Continue Reading
On January 14, 2019, a district court in the Eastern District of Pennsylvania granted a nationwide preliminary injunction halting the application of final regulations governing religious and moral-based exemptions from the Affordable Care Act (“ACA”) mandate to cover contraceptives without cost sharing. The final regulations would have dramatically expanded the scope of existing exemptions and … Continue Reading
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
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
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
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
On Friday, September 13, 2013, the IRS released Notice 2013-54 and the DOL issued Technical Release 2013-03 in substantially identical form. This guidance, which is generally effective January 1, 2014, provides much needed clarification on the application of certain provisions of the Patient Protection and Affordable Care Act (“ACA”) (annual limits and preventive care) to … Continue Reading
As employers plan for paying various health care reform fees, one question that arises is whether the fees owed are tax deductible. In particular, it has been unclear whether the fees paid pursuant the Affordable Care Act to fund the Patient-Centered Outcomes Research Institute (“PCORI”) would be deductible business expenses under Section 162 of the … Continue Reading
On May 29, 2013, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued final regulations on implementing and expanding employment-based wellness programs. The rules set forth in the final regulations remain largely unchanged from the proposed rules issued on November 20, 2012. For example, as provided for in the proposed rules, … 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
Recognizing that expatriate group health plans may find it impossible, or nearly impossible, to comply with all of the relevant provisions of the Patient Protection and Affordable Care Act of 2010 (PPACA), the U.S. Labor Department, the U.S. Department of Health and Human Services (HHS) and the U.S. Treasury Department have recently released a joint … Continue Reading
