9-11-2015
Employee Benefits & Executive Compensation
IRS guidance on minimum value test for employer-sponsored health plans
The IRS issued a supplemental notice of proposed rule-making (and request for comments) regarding the “minimum value” test that most employer-sponsored health plans must satisfy to avoid penalties under the employer shared responsibility provisions of the ACA. The minimum value test generally requires plans to share at least 60% of the total allowed cost of benefits under the plan. Reinforcing the earlier guidance under Notice 2014–69, the proposed regulation would add a minimum coverage element to the test, requiring that health plans cover “substantial” coverage for inpatient hospitalization and physician services in addition to the 60% minimum cost-sharing.
8-28-2015
Employee Benefits & Executive Compensation
CMS released an updated operational guidance for group health plan insurers and certain self-insured plans to count employees for purposes of computing 2015 reinsurance fees as required by the ACA. These employee counts are due by November 16, 2015.
8-21-2015
Employee Benefits & Executive Compensation
The IRS has released another round of drafts to IRS Forms 1095-B and 1095-C and corresponding B series Instructions and C series instructions) (also still draft), as well as Publication 5223 explaining the use of substitute forms to meet filing and participant disclosure requirements.
7-31-2015
Employee Benefits & Executive Compensation
The IRS issued a “tax tip” reminding employers that “providers of health coverage” include employers of all sizes that provide self-insured coverage and as a result must file annual returns with the IRS. Self-insured employers with fewer than 50 full-time or full-time equivalent employees in the preceding calendar year should file Form 1095-B, while applicable large employers should report health coverage information on Form 1095-C.
Disclaimer:
These employee benefits “Bytes” are prepared on behalf of the American Bar Association Health Law Section, and are part of a weekly “Health Law Byte” e-mail publication that is available to ABA members. The weekly HL Byte publication includes updates from the other ABA Health Law Interest Groups: •Business & Transactions, •eHealth, Privacy & Security, •Employee Benefits & Executive Compensation, •Healthcare Facility Operations, •In-House Counsel Sub-Interest Group, •Healthcare Fraud & Compliance, •Healthcare Litigation & Risk Management, •Life Sciences, •Managed Care & Insurance, •Payment, & Reimbursement, •Physician Issues, •Public Health & Policy, •Tax & Accounting. If you are interested in this and other ABA Health Section benefits please visit: http://www.americanbar.org/groups/health_law.html