The government has continued to issue a number of regulations and other guidance on the Patient Protection and Affordable Care Act (PPACA) and related health care laws, including the following
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Employee Benefits
ACA Update: Government Issues Preliminary Cadillac Tax Guidance
By Hunton Andrews Kurth LLP on
Posted in Employee Benefits
The IRS recently issued Notice 2015-16 addressing the excise tax on high cost employer-sponsored health coverage enacted under the Affordable Care Act.…
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ACA UPDATE: IRS Issues Final Forms And Instructions For Employer Coverage Reporting
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The IRS recently issued final versions of the new Forms 1094-B, 1095-B, 1094-C and 1095-C, along with related final Instructions. These forms are for reporting of coverage in 2014, but are expected to be similar for reporting for 2015.…
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ACA UPDATE: New Proposed Rules And Template For Group Health Plan SBCs
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In December 2014, the government issued new proposed rules regarding the requirements for providing a summary of benefits and coverage (SBC). Simultaneous with the proposed rules, the government also published an updated SBC template and uniform glossary.…
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Illinois Enacts Auto-Enrollment Savings Program for Private Sector Employees
On January 4, 2015, Illinois Governor Pat Quinn signed into law the Illinois Secure Choice Savings Program Act, which will require private sector employers to make automatic payroll deductions, and place the deductions into a state-run savings plan for the benefit of employees.…
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ACA UPDATE: IRS Issues Draft Forms And Instructions For Employer Coverage Reporting
By Hunton Andrews Kurth LLP on
Posted in Employee Benefits
The IRS recently issued draft versions of the new Forms 1094-B, 1094-C, 1095-B and 1095-C (the “Forms”) along with related draft Instructions.…
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ACA Update: Self-Insured Health Plans Required To Obtain Health Plan Identifier
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The Affordable Care Act required the Department of Health and Human Services (HHS) to establish a national health plan identifier (HPID) program under the HIPAA standard transactions rules. The resulting HHS rules generally require all HIPAA-covered entities, including self-insured plans with more than $5 million in annual claims, to obtain a HPID by November 5, 2014. Small self-insured health plans (i.e., those with annual claims of $5 million or less) will be required to obtain a HPID by November 5, 2015.
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New Commuter Benefits Requirement for San Francisco Bay Area Employers
By Hunton Andrews Kurth LLP on
Posted in Employee Benefits
Starting September 30, 2014, many employers in the greater San Francisco Bay Area will be required to provide commuter benefits to their employees as part of the “Bay Area Commuter Benefits Program.”…
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Final ACA 90-Day Waiting Period Rule on Use of Orientation Periods
By Hunton Andrews Kurth LLP on
Posted in Employee Benefits
On June 25, the government issued final rules regarding the use of “bona fide employment-based orientation periods” in connection with the Affordable Care Act’s 90 day waiting period limits. These final rules largely track the proposed rules issued in February.…
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CGL Insurer Must Defend Alleged ERISA Violations Where Factual Allegations Create a Possibility of Coverage
In Euchner-USA, Inc. v. Hartford Cas. Ins. Co., No. 13-2021-cv, 2014 U.S. App. LEXIS 10797 (2d Cir. June 10, 2014), the United States Court of Appeals for the Second Circuit found that an insurer must defend its insured in a case alleging ERISA violations because the facts alleged (as opposed to the embedded legal…