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Category Archives: Affordable Care Act

IRS Releases Guidance for Employers Offering Individual Coverage HRAs

On September 27, the Internal Revenue Service (IRS) released proposed regulations on the application of the Affordable Care Act’s (ACA) employer shared responsibility provisions to a new type of Health Reimbursement Arrangement (HRA) available starting in 2020.  In June 2019, … Continue reading

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IRS Confirms ACA Pay or Play Penalties Still Apply

Overview The IRS Office of Chief Counsel recently released an information letter regarding the employer shared responsibility (pay or play) penalties under the Affordable Care Act (ACA). This information letter confirms that the pay or play penalties continue to apply … Continue reading

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2020 HSA Contributions

IRS Releases 2020 HSA Contribution Limits and HDHP Deductible and Out-of-Pocket Limits In Rev. Proc. 2019-25, the IRS released the inflation adjusted amounts for 2020 relevant to HSAs and high deductible health plans (HDHPs). The table below summarizes those adjustments … Continue reading

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PCORI Fees Due By July 31, 2019

REMINDER: PCORI Fees Due By July 31, 2019 Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2019 deadline for paying fees that fund the Patient-Centered Outcomes Research Institute … Continue reading

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Client alert post

CMS Extends Transition Relief for Non-Compliant Plans through 2020 On March 25, 2019, the Centers for Medicare & Medicaid Services (CMS) announced a one-year extension to the transition policy (originally announced November 14, 2013 and extended five times since) for individual … Continue reading

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DOJ SUPPORTS FEDERAL COURT RULING INVALIDATING THE ACA OVERVIEW

DOJ SUPPORTS FEDERAL COURT RULING INVALIDATING THE ACA OVERVIEW   HIGHLIGHTS A federal judge ruled that the entire ACA is invalid due to the elimination of the individual mandate penalty. This ruling will likely be taken up by the Supreme … Continue reading

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HSA eligible expenses includible vs non-includible

You probably already know that can use your health savings account (HSA) to pay for specific expenses. However, there are rules as to what you can and cannot use your HSA to pay for. This distinction is referred to as … Continue reading

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Medicare Part D Disclosures due by March 1, 2019 for Calendar Year Plans

  OVERVIEW Group health plan sponsors are required to complete an online disclosure form with the Centers for Medicare & Medicaid Services (CMS) on an annual basis and at other select times, indicating whether the plan’s prescription drug coverage is … Continue reading

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Proposed Notice of Benefit and Payment Parameters for 2020

    OVERVIEW On Jan. 24, 2019, the Department of Health and Human Services (HHS) published its proposed Notice of Benefit and Payment Parameters for 2020. This proposed rule describes benefit and payment parameters under the Affordable Care Act (ACA) … Continue reading

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2019 Health Plan Compliance Deadlines

2019 Health Plan Compliance Deadlines Employers must comply with numerous reporting and disclosure requirements throughout the year in connection with their group health plans. This Compliance Overview explains key 2019 compliance deadlines for employer-sponsored group health plans. It also outlines … Continue reading

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