Play or Pay Penalty Delayed To 2015

On July 2, 2013 the Department of the Treasury and the White House used their blogs to announce that the employer reporting requirements, and the employer shared responsibility/Play or Pay penalty, are being delayed until 2015.  The Treasury said that it will provide a formal announcement and additional details next week. Background The employer shared […]

PPACA: Individual Grace Period

Effective Date for Individual Mandate Delayed For Some People On June 26, 2013 the IRS unexpectedly issued a notice that gives individuals who are eligible for coverage under an employer-sponsored health plan, but who have not elected coverage under that plan, until the start of the 2014 plan year to enroll in the plan.  Employees […]

U.S. Supreme Court Rules Legally-Married Same-Sex Spouses Entitled to Federal Recognition and Lifts California Ban on Same-Sex Marriage

The United States Supreme Court has issued two decisions that expand same-sex marriage rights. In the first, United States v. Windsor, No. 12-307 (June 26, 2013), the Court ruled unconstitutional a law denying federal recognition of legally-married same-sex couples. In the second, Hollingsworth, et al. v. Perry, No. 12-144 (June 26, 2013), the Court effectively […]

COMPLIANCE ALERT!! Final “SHOP” Regulations Issued

On June 4, 2013, the Department of Health and Human Services (“HHS”), Centers for Medicare & Medicaid Services (“CMS”), issued final regulations implementing the provisions of the Affordable Care Act (“ACA”) related to the establishment and operation of the Small Business Health Options Program (“SHOP”). The final regulations delay by one year the implementation of […]

PCORI Fee Due Date

By July 31, 2013, most issuers of health insurance policies and plan sponsors of self-insured health plans must pay a fee of $1 per covered life as a result of new provisions in the Patient Protection and Affordable Care Act.  The fee will partially fund the Patient-Centered Outcome Research Institute (“PCORI”), which is a private, […]

PPACA: Certificates of Creditable Coverage

Affects all plans, whether fully insured, self-funded or grandfathered, and regardless of employer size, as of Jan. 1, 2015. Because pre-existing condition limitations will not be permitted after the start of the 2014 plan year, certificates of creditable coverage would not need to be provided after Dec. 31, 2014.  (This date would apply regardless of […]

AGENCIES ISSUE FINAL RULES ON WELLNESS PROGRAMS

On May 29, 2013 the Department of Health and Human Services, the Internal Revenue Service and the Department of Labor jointly issued a final rule that addresses how wellness programs must operate under PPACA beginning in 2014. In many respects the final rules carry forward the rules that have been in effect for wellness programs […]

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