- 2019 ACA Overview & Compliance Checklist¬†(pdf) The Affordable Care Act (ACA) has made a number of significant changes to group health plans since the law was enacted in 2010. Many of these key reforms became effective in 2014 and 2015, including health plan design changes, increased wellness program incentives and the employer shared responsibility penalties.¬†¬†Certain changes to some ACA requirements take effect in 2019 for employers sponsoring group health plans, such as increased dollar limits. To prepare for 2019, employers should review upcoming requirements and develop a compliance strategy.
- Draft Forms for 2019 ACA Reporting Released¬†(pdf)¬† On Nov. 13, 2019, the Internal Revenue Service (IRS) released¬†draft 2019 forms and instructions¬†for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.¬† The draft 2019 forms and instructions are substantially similar to the final 2018 versions.¬†Note that Section 6055 reporting continues to be required, despite the fact that the individual mandate penalty has been reduced to $0.
- President Trump Signed Executive Order Intended to Increase Health Care Price Transparency¬†(pdf)¬† On Monday, June 24, 2019, President Donald Trump signed an executive order designed to increase pricing and quality transparency in health care. The president‚Äôs executive order is the latest move that the Trump administration has taken to address rising health care costs.
- Federal Court Strikes Down Association Health Plan Rules¬†(pdf)¬† On March 28, 2019, a federal judge ruled that parts of the Trump administration‚Äôs 2018 final rule on association health plans (AHPs) were invalid. The court directed the Department of Labor (DOL) to reconsider how the remaining provisions of the final rule are affected.¬† In its ruling, the court stated that the final rule was an ‚Äúend-run‚ÄĚ around the Affordable Care Act (ACA) and that the DOL exceeded its authority under ERISA.
- Affordability Percentages Will Increase for 2019 (pdf)¬† On May 21, 2018, the Internal Revenue Service (IRS) issued Revenue Procedure 2018-34¬†to index the contribution percentages in 2019 for purposes of determining affordability of an employer‚Äôs plan under the Affordable Care Act (ACA)
- HHS Moves for More Drug Price Transparency¬†(pdf)¬† Beginning in May of last year, the Trump administration began searching for ways to curb out-of-control prescription drug costs‚ÄĒreferring to the initiative as¬†American Patients First. This effort is finally seeing some traction, with the administration publishing its first final rule on the matter.
- President Trump Says Vote on GOP Health Care Plan to Come After 2020 Election¬†(pdf) On Monday, April 1, 2019, President Donald Trump stated in a series of tweets that a vote on a Republican Party (GOP) replacement health care plan for the Affordable Care Act (ACA) won‚Äôt take place until after the 2020 elections.
- Furnishing Deadline Delayed for 2018 ACA Reporting¬†(pdf)¬†On 11/29/2018, the Internal Revenue Service (IRS) issued Notice 2018-94 to: Extend the due date for furnishing forms under Sections 6055 & 6056 for 2018 from Jan. 31, 2019, to March 4, 2019; and Extend good-faith transition relief from penalties related to 2018 information reporting under Sections 6055 & 6056.¬† Notice 2018-94 does not extend the due date for filing forms with the IRS for 2018. The due date for filing with the IRS under Sections 6055 & 6056 remains Feb. 28, 2019 (April 1, 2019, if filing electronically, since March 31, 2019, is a Sunday).
- HHS Extends Transition Policy for Non-ACA Compliant Health Plans¬†(pdf)
On April 9, 2018, the Department of Health and Human Services (HHS) extended an existing transition policy for certain health plans that do not comply with the Affordable Care Act (ACA) for an additional year, to policy years beginning on or before Oct. 1, 2019.¬† In states that allow it, health insurance issuers have the option of renewing current policies for current enrollees without adopting all of the ACA‚Äôs market reforms that took effect in 2014.¬† Originally announced in 2013, the transition policy has already been extended several times.
- IRS Confirms ACA Mandate Penalties Still Effective¬†(pdf)
The Internal Revenue Service (IRS) Office of Chief Counsel has recently issued several information letters regarding the Affordable Care Act‚Äôs (ACA) individual and employer mandate penalties.
- Trump Announces Plan to Combat Surprise Medical Billing¬†(pdf)¬† On May 9, 2019, President Donald Trump delivered a speech criticizing the practice of surprise medical billing. He announced a general plan of attack and hinted at a few specifics for curbing the trend.
- House and Senate Pass Tax Reform Bill (pdf)
On Dec. 2, 2017, the tax reform bill, called the¬†Tax Cuts and Jobs Act, passed both the U.S. Senate and the U.S. House of Representatives.¬†The bill is now expected to be signed into law by President Trump by the end of the day.
- 2018 ACA Overview & Compliance Checklist (pdf)
The Affordable Care Act (ACA) has made many significant changes to group health plan since the law was enacted in 2010.¬† Certain changes to some ACA requirements take effect in 2018 for employers sponsoring group health plans, such as increased dollar limits.¬† To prepare for 2018, employers should review upcoming requirements and develop a compliance strategy.¬† This ACA overview provide an ACA compliance checklist for 2018.
- House Republicans Pass Amended AHCA (pdf)
On May 4, 2017, members of the U.S. House of Representatives voted along party lines to pass an amended version of the American Health Care Act ‚Äď proposed legislation to repeal and replace the ACA. The AHCA will now move on to be considered by the Senate. This provides an overview of the proposed legislation and its potential impact going forward.
- Trump Signs Executive Order on the ACA (pdf)
On Jan. 20, 2017, President Donald Trump signed an executive order addressing the Affordable Care Act (ACA), as his first act as president. The order states that it is intended to ‚Äúto minimize the unwarranted economic and regulatory burdens‚ÄĚ of the ACA until the law can be repealed and eventually replaced.
- Identifying Full-Time Employees: The Monthly Measurement Method (pdf)
Under the ACA, applicable large employers may be subject to a penalty if they do not offer health coverage to their full-time employees. This Legislative Brief provides an overview of the monthly measurement method for identifying full-time employees.
- Post-Election ACA Round-Up¬†(pdf)
If you were unable to attend our client webinar on Nov. 17, 2016, attached is the presentation outlining an update on ACA and potential changes due to the recent election, or you can select this link and register to view the replay of the webinar.
- 2017 Compliance Checklist¬†(pdf)
Although many key reforms under the Affordable Care Act (ACA) became effective in 2014 and 2015, additional reforms are effective in 2017. To prepare, employers should review upcoming requirements and develop a compliance strategy.
- Overtime Rule Blocked by Federal Court (pdf)¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† ¬† On Nov. 22, 2016, a federal judge in Texas issued a preliminary injunction, halting the enforcement of the Department of Labor‚Äôs (DOL) new overtime rule until further notice. The rule, which was set to take effect on Dec. 1, 2016, would have increased the salary threshold for the ‚Äúwhite collar overtime exemptions” to $47,476 per year.