August was a generally slow month with a few important updates for the benefits industry. Notably the Internal Revenue Service (IRS) issued draft instructions for its reporting forms relating to the Patient Protection and Affordable Care Act’s (ACA) employer-shared responsibility requirements. The draft instructions, although generally unremarkable, did contain new language regarding reporting on health […]
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IRS Releases Draft 2015 Instructions for 6055/6056 Reporting
Background Under the Patient Protection and Affordable Care Act (ACA), individuals are required to have health insurance while applicable large employers (ALEs) are required to offer health benefits to their full-time employees. In order for the Internal Revenue Service (IRS) to verify that (1) individuals have the required minimum essential coverage, (2) individuals who request […]
Read more6055 Reporting, HRAs, and “Supplemental Coverage”
The Affordable Care Act (ACA) implemented section 6055 of the Internal Revenue Code, which requires IRS reporting from any entity that provides “minimum essential coverage” (MEC) to individuals. Employers who are applicable large employers (ALEs) have related reporting obligations under section 6056. Beginning in 2013, during the proposed rulemaking stage, the government was clear that […]
Read moreVeterans with TRICARE; VA Coverage Won’t Count Toward Applicable Large Employer Status
The Surface Transportation and Veterans Health Care Choice Improvement Act (STVHCC) of 2015 was signed into law by President Obama on July 31, 2015. The Act, also known as H.R. 3236, is focused on surface transportation programs but affects rules regarding how to count employees under the Patient Protection and Affordable Care Act (ACA) as […]
Read moreDOL Issues Guidance on Classification of Independent Contractors
The Department of Labor (DOL) has issued an “Administrator’s Interpretation” to assist employers in determining if a worker is an employee or an independent contractor. The DOL has determined that many employers are incorrectly classifying employees as independent contractors, which can harm the worker and open the employer up to various liabilities. Unfortunately, there is […]
Read moreCompliance Recap // July 2015
July brought the benefits industry increased fines relating to the Patient Protection and Affordable Care Act (ACA) as well as some much-anticipated updates and information on a variety of subjects. A trade bill passed in early July increased penalties for employers that fail to file IRS forms relating to the ACA’s play or pay provision, […]
Read moreMid-Size Employers: Transition Relief and Community Rating
The employer shared responsibility (i.e., “play or pay”) requirements went into effect in 2015 for large employers only (those with 100 or more full-time or full-time-equivalent employees). Even though they generally will not be liable for penalties until 2016, mid-size employers (employers with 50 to 99 full-time or full-time-equivalent employees) will need to report on […]
Read moreTrade Bill Increases ACA Reporting Penalties; Reinstates Tax Credit
Most employers are familiar with the penalties assessed to applicable large employers that fail to offer minimum essential coverage that is minimum value and affordable. In addition to being required to offer coverage, employers (all applicable large employers, and all employers with self-funded plans regardless of size) are required to complete IRS reporting forms under […]
Read moreCompliance Recap // June 2015
June was a busy month, with multiple updates from regulatory agencies as well as two important Supreme Court opinions that impacted the world of employer benefits. As the Supreme Court wrapped up the October 2014 term, it has granted petitions for the October 2015 term, which will ultimately impact ERISA plans. The IRS updated its […]
Read moreIRS Releases Draft 2015 Forms for 6055/6056 Reporting
Background Under the Patient Protection and Affordable Care Act (ACA), individuals are required to have health insurance while applicable large employers (ALEs) are required to offer health benefits to their full-time employees. In order for the Internal Revenue Service (IRS) to verify that (1) individuals have the required minimum essential coverage, (2) individuals who request […]
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