compliance

Compliance Recap | November 2019

November was a busy month in the employee benefits world. The Internal Revenue Service (IRS) released draft 2019 instructions for Forms 1094-B, 1095-B, 1094-C, and 1095-C. The IRS also released health plan limits and various compensation, benefit, and contribution levels under qualified ...

IRS Releases Draft Forms and Instructions for 2019 ACA Reporting

Background Under the Patient Protection and Affordable Care Act (ACA), applicable large employers (ALEs) are required to offer health benefits to their full‑time employees and individuals are required to have health insurance, although the penalty is $0 for failing to have minimum essential ...

Proposed Rules on Coverage Transparency and Final Rules on Hospital Price Transparency

On November 15, 2019, the Internal Revenue Service (IRS), Department of Labor (DOL), and the Department of Health and Human Services (HHS) (collectively, Departments) released proposed rules on coverage transparency. The proposed rules seek to give an estimate of plan participants’ potential ...

Compliance Recap | October 2019

October was a relatively quiet month in the employee benefits world. The U.S. District Court for the Northern District of Texas vacated portions of the current rule implementing Section 1557 that prohibit discrimination on the basis of gender identity and pregnancy termination. The U.S. Court ...

Contraception Mandate Rolled Back for Employers

The Department of the Treasury (Treasury), Department of Labor (DOL), and Department of Health and Human Services (HHS) (collectively, the Departments) released two final rules on November 7, 2018, regarding contraceptive coverage exemptions. These rules finalize the Departments’ interim final ...

Update on Nondiscrimination Regulations for Health Care Providers

The Patient Protection and Affordable Care Act (ACA) Section 1557 provides that individuals shall not be excluded from participation in, denied the benefits of, or be subjected to discrimination under any health program or activity which receives federal financial assistance from the Department ...

Update on Nondiscrimination Regulations

The Patient Protection and Affordable Care Act (ACA) Section 1557 provides that individuals shall not be excluded from participation in, denied the benefits of, or be subjected to discrimination under any health program or activity which receives federal financial assistance from the Department ...

Compliance Recap | September 2019

September was a busy month in the employee benefits world. The U.S. Senate confirmed Eugene Scalia as the new Secretary of the Department of Labor (DOL). The Internal Revenue Service (IRS) published proposed rules regarding affordability safe harbors and Section 105(h) nondiscrimination rules ...

Medicare Part D Notices

If your health benefit plan covers any employee, or their covered dependents, who is eligible for Medicare, this applies to you. If you know that your plan does not cover any Medicare eligible individuals (employee or dependent) then you do not need to send this notice. If your medical plan ...

Final FAQs, Model Disclosure Form, and Enforcement Fact Sheet Regarding Mental Health and Substance Use Disorder Parity

The U.S. Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (collectively, the “Departments”) released final FAQs About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 39. The Departments respond to FAQs as part of ...