Category Archives: Affordable Care Act
2023 Open Enrollment Checklist
To prepare for open enrollment, group health plan sponsors should be aware of the legal changes affecting the design and administration of their plans for plan years beginning on or after Jan. 1, 2023. Employers should review their plan documents … Continue reading
Agencies Release First Rule on the No Surprises Act
On July 13, 2021, the DOL, HHS, and IRS released a joint Interim Final Rule implementing specified provisions of the No Surprises Act, a new law included within the Consolidated Appropriations Act, 2021. The No Surprises Act addresses, among other … Continue reading
President Trump Issues Executive Orders Intending to Lower the Cost of Prescription Drugs
On July 24, 2020, President Trump issued several Executive Orders intending to lower prescription drug costs by (1) modifying anti-kickback laws to lower drug prices, (2) reducing trade barriers to increase importation of drugs and lower prices, and (3) improving … Continue reading
CMS Extends Transition Relief for Non-Compliant Plans through 2021
On January 31, 2020 the Centers for Medicare & Medicaid Services (CMS) announced a one-year extension to the transition policy (originally announced November 14, 2013 and extended six times since) for individual and small group health plans that allows issuers … Continue reading
Congress Expected to Pass Spending Bill that Repeals Three Major ACA Taxes, Extends PCORI
On December 17, 2019, the House and Senate agreed to a bipartisan legislative package of spending bills to avoid a government shutdown. This package of bills is collectively referred to as the Further Consolidated Appropriations Act, 2020 (the “Act”). The … Continue reading
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
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
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
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
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
