1 What s News in Tax Analysis That Matters from Washington National Tax Health Insurance Companies and Employers: There s a New Fee to Consider A new fee may apply to issuers of health insurance policies and employers who sponsor self-funded health plans. As this article explains in more detail, the Affordable Care Act imposes a fee on certain health insurance policies and self-funded plans for policy and plan years ending in 2012, the first due date for the fee is July 31, KPMG LLP does not assist clients in designing, implementing, or amending employee benefit plans. Background and Effective Dates Monday, March 25, 2013 by Veena K. Murthy, Washington National Tax Veena K. Murthy is a director in WNT s Compensation and Benefits Technical Support group. Veena thanks Roger Bailey, a former intern, for his assistance with this article. The Patient Protection and Affordable Care Act of 2010 (the Affordable Care Act ) established the Patient Centered Outcomes Research Institute (the PCORI ) to assist patients, clinicians, purchasers, and policy-makers in making informed health decisions. 1 The Affordable Care Act also created the Patient Centered Outcomes Research Trust Fund to financially support the PCORI. To fund the trust, Congress enacted Code sections 4375 and 4376, which impose an annual fee on issuers of "specified health insurance policies" and plan sponsors of "applicable self-insured health plans," respectively. This means that employers with self-funded health and welfare arrangements, as well as health insurance companies, are subject to the fee unless otherwise excepted. The fee applies for policy years (insured plans) and plan years (self-insured plans) ending on dates falling on or between October 1, 2012, and September 30, Generally, the fee is a dollar multiplier ($1 for policy or plan years ending during the 2013 fiscal year) per person for the average number of lives covered. The dollar multiplier increases to $2 in the next fiscal year, and is indexed thereafter. Under current rules, the fee will no longer apply to policy and plan years ending after September 30, On December 6, 2012, the IRS and Treasury published final regulations to provide guidance on the applicability, liability, calculation, payment, and 1 Patient Protection and Affordable Care Act, Pub. L. No , 124 Stat. 728, sec. 6301, 1181(c), 728, (2010). KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative, a Swiss entity.
2 Health Insurance Companies and Employers: There s a New Fee to Consider page 2 reporting of the fee. The regulations indicate that the fee will be required to be paid and reported on Form 720, Quarterly Federal Excise Tax Return, once a year by July 31 of the calendar year immediately following the last day of the applicable policy or plan year. In other words, for calendar year plans ending December 31, 2012, the fee and filing is due July 31, Application of PCORI Fee to Insurers Section 4375 imposes the fee on each issuer of a specified health insurance policy, which is defined as any accident or health policy (including a policy under a group health plan) issued with respect to individuals residing in the United States. This includes prepaid health coverage arrangements in which fixed payments or premiums are received as consideration for any person s agreement to provide or arrange for the provision of accident or health coverage to residents of the United States. 2 The regulations clarify that these prepaid health coverage arrangements specifically include arrangements such as health maintenance organization (HMO) contracts as well as hospital and medical service certificates, policies, and plan contracts. 3 The regulations further clarify that a specified health insurance policy includes accident and health coverage to an active employee, former employee, or qualifying beneficiary, as continuation coverage required under the Consolidated Omnibus Reconciliation Act ( COBRA ) or similar continuation coverage under other federal or state law. 4 Section 4375 provides that a specified health insurance policy does not include any insurance if substantially all of its coverage is one of the following excepted benefits, described in section 9832(c): Accident or disability income insurance Coverage issued as a supplement to liability insurance Liability insurance (including general liability insurance and automobile liability insurance) Unless otherwise indicated, references to section or sections in this article are to the Internal Revenue Code of 1986 (the Code ), as most recently amended, or to the U.S. Treasury Department regulations (the regulations ), as most recently adopted or amended Workers' compensation Automobile medical payment insurance Section 4375(c). Section (b)(2). Section (b)(1)(ii).
3 Health Insurance Companies and Employers: There s a New Fee to Consider page 3 Credit-only insurance Coverage for on-site medical clinics Similar insurance coverage under which benefits for medical care are secondary or incidental to other insurance benefits If offered separately: limited scope dental or vision benefits, long-term care, nursing home care, home health care, community-based care If offered as an independent, non-coordinated benefit: coverage for a specified disease or illness, hospital indemnity or other fixed indemnity insurance If offered as a separate insurance policy: Medicare supplemental health insurance, coverage supplemental to military medical and dental coverage under 10 U.S.C. 55, and similar supplemental coverage In addition to the above list, the regulations clarify that the fee does not apply to group policies issued primarily for employees working and residing outside of the United States, stop-loss policies, and indemnity reinsurance policies. 5 Application of PCORI Fee to Sponsors of Self-Insured Plans The fee also applies to sponsors of applicable self-insured health plans (also commonly referred to as self-funded plans) under section Selfinsured plans include any plan offering health or accident coverage that is not provided by an insurance company, is funded by employer and/or employee contributions and payments, and is established and maintained for the benefit of current or former employees by: One or more employers One or more employee organizations One or more employers and employee organizations jointly A voluntary employees beneficiary association ( VEBA ) under section 501(c)(9) 5 Section (b)(1).
4 Health Insurance Companies and Employers: There s a New Fee to Consider page 4 A multiple-employer welfare arrangement, rural electric cooperative, or rural telephone cooperative association, or An organization described in section 501(c)(6) (certain nonprofit organizations that are business leagues, chambers of commerce, realestate boards, boards of trade, or professional football leagues) 6 Because of the variety of self-insured plans, the term plan sponsor can refer to a single employer or employee organization that establishes or maintains a plan, or in the case of an arrangement with more than one establishing party the joint board of trustees or similar group of the parties representatives. 7 Note that retiree-only plans, health reimbursement arrangements ( HRAs ), and health flexible spending arrangements ( FSAs ) that do not fall under section 9832(c) are nevertheless treated as self-insured plans for this purpose. 8 However, self-insured plans do not include: FSAs that are excepted benefits under section 9832(c) and related regulations Employee assistance, disease management, and wellness programs that do not provide significant benefits in the nature of medical care or treatment Plans established and designed specifically to primarily cover employees who are working and residing outside the United States Determining the Plan Sponsor Responsible for the Fee The regulations provide general information on determining the plan sponsor responsible for the fee. Generally, this is the entity within an employer organization that established and maintains the plan. When the plan covers employees of entities within a controlled group, the plan sponsor is the person identified as such by the terms of the plan document, provided the designation is made in writing and the person has consented to the designation in writing no later than the due date for the return in which the PCORI fee must be paid. If the plan sponsor is not Sections 4376(c)(2) and (b)(1)(i). Section 4376(b)(2). Sections (b)(1)(ii) and (iii); see Preamble Section II to the final regulations regarding retiree plans.
5 Health Insurance Companies and Employers: There s a New Fee to Consider page 5 identified in writing, each employer that establishes or maintains the plan with respect to its employees must separately file a Form 720 and pay the fee based on the covered lives attributable to that employer s employees (including spouses, dependents, and other beneficiaries). 9 Note also that the trustee of a VEBA is considered a plan sponsor for this purpose. VEBAs are generally tax-exempt trusts for self-funded health and welfare plans and are often implemented by employers with retiree medical plans, FSAs, dependent care savings arrangements, or other eligible health and welfare plans. However, a VEBA that is merely serving as a funding vehicle for a plan that is established and maintained by an employer is not a plan sponsor, and instead the employing entity is considered the plan sponsor for purposes of the fee. 10 Residence of Participants The regulations provide guidance for determining the residence of individuals covered under plans and policies. This is helpful because a specified health insurance policy does not include one issued with respect to individuals not residing in the United States, and an applicable self-insured plan does not include a self-funded expatriate plan if the facts and circumstances support that the plan was designed specifically to cover primarily employees who are working and residing outside of the United States. A U.S. resident is a person who has a place of abode in the United States (including U.S. possessions). 11 To determine a plan participant s place of abode, the issuer or sponsor may use its most recent address on file for the primary insured participant (the individual eligible for coverage other than due to his or her status as a spouse, dependent, or other beneficiary of another insured individual). Other individuals receiving coverage via the primary insured participant may be treated as sharing the same abode as the primary insured participant. Reporting Taxpayers subject to sections 4375 and 4376 must report the fees on Form 720 on an annual basis. Although most Form 720 excise taxes are Sections (b)(2)(i)(G) and (H). Section (b)(2)((i)(F). Section (a)(2).
6 Health Insurance Companies and Employers: There s a New Fee to Consider page 6 deposited semiannually and reported quarterly, for purposes of the fees outlined in sections 4375 and 4376, the taxpayer is only required to report and pay the PCORI fee once a year by July 31. Calculation of the Fee The general fee formula is essentially the same for specified health insurance policies and applicable self-insured health plans. For plan or policy years ending on or before September 30, 2013, the taxpayer must pay $1 per person for the average number of lives covered. The dollar multiplier increases to $2 per person for the plan or policy year ending after September 30, For plan years ending after September 30, 2014, and until September 30, 2019, the fee will increase based on increases in the projected per capita amount of the National Health Expenditures released by the Department of Health and Human Services ( HHS ) before the beginning of the applicable fiscal year. 12 The fee will therefore be an adjustable amount based on the HHS evaluation of healthcare costs. Determination of Average Number of Lives Covered Insurance policies The regulations provide four methods that issuers can use to determine the average number of lives covered under a given policy: 1. Actual Count Method: The issuer calculates a simple average by adding the total number of lives covered for each day during the policy year, and dividing this sum by the number of days in the policy year. 2. Snapshot Method: The issuer counts the total number of lives covered on one or more days each quarter (so long as the count is made on the same number of days each quarter). The days on which the counts are made must be consistent (e.g., the count is always on the first day of the quarter, last day of the month, or some similar pattern, provided that for each quarter the date or dates used are within three days of the date or dates used in the first quarter). These snapshot 12 Sections 4375(d) and 4376(d).
7 Health Insurance Companies and Employers: There s a New Fee to Consider page 7 counts are then added together and divided by the number of days on which a count was taken, producing an average. 3. Member Months Method: The issuer uses the member months reported on the National Association of Insurance Commissioners ( NAIC ) Supplemental Health Care Exhibit filed for the calendar year in question. The total number of lives reported as member months for a given year is divided by 12 to produce an average number of lives covered. 4. State Form Method: If the issuer is not required to file an NAIC financial statement, the issuer may instead use a state form that reports member lives in the same manner as membership months, and that is filed in the issuer s state of domicile. Calculations for this method are identical to those for the Member Months Method. Self-insured plans The regulations also provide four methods that plan sponsors can use to calculate the average number of lives covered under a self-insured plan: 1. Actual Count Method: The same Actual Count Method described above for policy issuers (based on the plan year rather than policy year). 2. Snapshot Count Method: The same as the Snapshot Method described above for policy issuers (based on the plan year rather than policy year). 3. Snapshot Factor Method: The same as the Snapshot Method described above for policy issuers (based on the plan year rather than policy year), except that the number of lives covered on a given day is equal to the sum of the number of participants with self-only coverage on that date, plus the product of 2.35 and the number of participants who have other covered beneficiaries. Example: A sponsor counts a plan s participants on the first day of every quarter. At the beginning of the first quarter, there are 1,000 self-only participants, and 500 other participants. The count for this specific snapshot would then be 1,000 + (500 x 2.35), or 2,175 participants. This computation would be repeated for all
8 Health Insurance Companies and Employers: There s a New Fee to Consider page 8 additional counts, and the results would be averaged together at the end of the plan year. 4. Form 5500 Method: The sponsor calculates lives based on the number of participants reported on Form 5500 (Annual Return/Report of Employee Benefit Plan) that is filed for the applicable self-insured health plan for that plan year, provided the Form 5500 is filed no later than the due date for the fee imposed by section 4376 for that plan year (i.e., July 31, 2013, for a calendar year plan ending December 31, 2012). For a plan offering self-only coverage, the average number of covered lives is equal to the sum of the total participants reported as covered at the beginning and end of the plan year, divided by two. For a plan offering self-only coverage and coverage other than self-only coverage, the average number of lives equals the sum of total participants reported as covered at the beginning and end of the plan year. 13 The regulations require consistency in use of a method. Generally, policy issuers and plan sponsors must use the same method consistently during a policy or plan year. However, a plan sponsor may use a different method from one plan year to the next. Overlapping Policies and Plans When accident and health coverage is provided to one individual through more than one policy or self-insured arrangement, the regulations clarify how the fee applies. The fee imposed on the issuer of a specified health insurance policy under section 4375 is separate from the fee imposed on the plan sponsor of an applicable self-insured plan, and each fee is based on the average number of lives covered under the policy or plan during the policy or plan year. Multiple self-insured arrangements established and maintained by the same plan sponsor and with the same plan year are subject to a single fee. For example, if an employee is covered under an HRA which is integrated with another self-insured health plan of the plan sponsor under which the employee is also covered, the sponsor pays a single fee with respect to that employee for both plans. This may also apply to an 13 Section (c)(2)(v).
9 Health Insurance Companies and Employers: There s a New Fee to Consider page 9 umbrella cafeteria plan that includes various self-insured arrangements. However, note that a single fee does not apply if the arrangements or plans have different plan years or different plan sponsors. However, because sections 4375 and 4376 are separate sections, the fee applies under each statute in cases when a healthcare arrangement can simultaneously be considered a self-insured plan and a specified health insurance policy. For example, if an employee is covered by both a group insurance policy and an HRA, the group insurance policy falls within the definition of a specified health insurance policy to which section 4375 applies a fee to the issuer, and the HRA falls within the definition of an applicable self-insured health plan to which section 4375 applies a fee to the plan sponsor. 14 Key Clarifications from the Final Regulations The fee applies to retiree-only specified health insurance policies and applicable self-insured plans that provide accident and health coverage, even though such plans may be exempted from other requirements under the Affordable Care Act. The fee applies to COBRA continuation coverage that provides accident and health coverage, regardless of how it is provided (through the individual market, to an active employee as part of a group health plan, or as continuation coverage to an active employee, former employee, or otherwise qualifying beneficiary). An exception from the fee applies to any insurance policy or selfinsured plan that provides for an employee assistance program, disease management program, or wellness program that does not provide significant benefits in the nature of medical care or treatment. An exception from the fee applies to any group insurance policy or self-insured plan if the facts and circumstances show that the policy or plan was designed (and issued in the case of policies) specifically to cover primarily employees who are working and residing outside of the United States. 14 Section (b)(iii); see Preamble Sections IV, V, and VI to final regulations.
10 Health Insurance Companies and Employers: There s a New Fee to Consider page 10 If an employee is covered by both a group insurance policy and an HRA, a separate fee applies under sections 4375 and 4376, since one plan is insured and one plan is self-funded. Similarly, if an employee is covered by both a group insurance policy and an FSA, a separate fee applies under sections 4375 and Calendar year self-insured plan sponsors subject to the fee can only use the Form 5500 method to determine the applicable covered lives subject to the fee if the Form 5500 is filed on or before July 31 following the plan year. That is, the Form 5500 method for counting lives cannot be used if the Form 5500 filing deadline is extended beyond July 31 following the end of the plan year, because this would result in the Form 5500 being filed after the date that the Form 720 filing and PCORI fee are due. Next Steps As described in this article, the PCORI fee applies to policy and plan years ending after September 30, 2012, and must be paid and reported by July 31 of the calendar year immediately following the last day of the applicable policy or plan year. Therefore, the first due date for the fee is July 31, The regulations do not permit or include rules for third-party reporting or payment of the PCORI fee. Employers that maintain self-funded plans and insurance policy issuers to whom the fee applies should begin to address any procedures and administration needed to ensure proper and timely payment and Form 720 reporting. In early April 2013, the IRS is expected to release a revised Form 720 and related instructions to address the reporting of the PCORI fee. Looking Ahead: Transitional Reinsurance Fee On December 7, 2012, HHS issued proposed regulations regarding the transitional reinsurance program under the Affordable Care Act. The program is designed to stabilize premiums in the individual health market, and is effective from 2014 through To support the program, a fee currently estimated at $63 per covered life will be assessed against insured and self-insured group health plans.
11 Health Insurance Companies and Employers: There s a New Fee to Consider page 11 Under the proposed regulations, the methodologies described for the PCORI fee to determine covered lives also apply to determine the covered lives for purposes of the transitional reinsurance fee. The transitional reinsurance fee will be collected annually by HHS, and determined based on the covered lives count, which is required to be submitted by November 15 of each year. The first due date for this count is November 15, 2014, with the fee payable afterwards. This additional fee underscores the importance of accurately measuring covered lives under group health plans and policies, as this affects employers and health insurers with respect to more than just the PCORI fee. The IRS also issued frequently asked questions confirming that the transitional reinsurance fee is tax deductible by plan sponsors as an ordinary and necessary business expense. In addition, the Department of Labor has indicated that these fees are permissible plan expenses under the Employee Retirement Income Security Act (ERISA) (which it has not indicated for the PCORI fee). KPMG s What's News in Tax is a publication from Washington National Tax that contains thoughtful analysis of new developments and practical, relevant discussions of existing rules and recurring tax issues. The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser. This article represents the views of the author or authors only, and does not necessarily represent the views or professional advice of KPMG LLP.
June 18, 2013 Author: Christine L. Keller, Mark C. Nielsen, Vivian Hunter Turner, Brigen L. Winters If you have questions, please contact your regular Groom attorney or any of the Health and Welfare attorneys
IRS Releases Final Regulations Imposing PCORI Fee on Sponsors of Fully Insured and Self-Insured Health Plans December 2012 The Internal Revenue Service (IRS) issued final regulations on December 5, 2012,
Part III Administrative, Procedural, and Miscellaneous Request for Comments on Funding of Patient-Centered Outcomes Research Through Fees Payable by Issuers of Health Insurance Policies and Self-Insured
IRS Issues Proposed Regulations on Research Fees The Affordable Care Act (ACA) created the Patient-Centered Outcomes Research Institute (Institute) to help patients, clinicians, payers and the public make
Self-funded Employer s Guide Transitional Reinsurance Fee and Patient-Centered Outcomes Research Institute Fee To fund some of the changes mandated by the Affordable Care Act (ACA), several new taxes and
HHS Final Rule on Transitional Reinsurance Fee Adds to Employer Costs March 2013 A transitional reinsurance fee is being added to the penalties and taxes imposed on employers and their fully insured and
INTERNATIONAL MEDICAL ADMINISTRATORS, INC. (IMA) Important Notice: ACA s PCORI Fee and Self Insured Plans Under the Affordable Care Act (ACA), your group health plan is required to pay a Patient Centered
Part III Administrative, Procedural, and Miscellaneous Interim Guidance on Informational Reporting to Employees of the Cost of Their Group Health Insurance Coverage Notice 2011-28 I. PURPOSE This notice
Federal Register / Vol. 77, No. 235 / Thursday, December 6, 2012 / Rules and Regulations 72721 and adding the word, customs before the word, station ; d. Paragraph (b)(1) is amended by: i. Removing the
INTERNATIONAL MEDICAL ADMINISTRATORS, INC. (IMA) Important Notice: ACA s Transitional Reinsurance Fee and Self Insured Plans Under the Affordable Care Act (ACA), your group health plan is required to pay
Vol. 16, 078 March 18, 2015 EY Payroll NewsFlash Initial proposed guidance now available on Cadillac tax for higher cost health coverage Currently, qualified employer group health coverage is generally
What s News in Tax Analysis That Matters from Washington National Tax The Impact of the Affordable Care Act on International Assignees and Their Health Care Plans Employers and individuals in the United
Reinsurance and other fees could impact employer health care costs To help offset the cost of coverage expansion and other provisions, the Patient Protection and Affordable Care Act (ACA) imposes a number
U.S. Department of Labor Employee Benefits Security Administration Washington, D.C. 20210 TECHNICAL RELEASE 2013-03 DATE: SEPTEMBER 13, 2013 SUBJECT: APPLICATION OF MARKET REFORM AND OTHER PROVISIONS OF
What s News in Tax Analysis That Matters from Washington National Tax IRS Issues Final Regulations Concerning Reporting of Health Care Coverage by Plan Sponsors and Health Insurers Employers are required
Issue One Hundred One March 2015 IRS ISSUES GUIDANCE ON CADILLAC TAX March 30, 2015 The Cadillac tax is scheduled to take effect in 2018. It will apply to employers or insurance carriers that sponsor plans
Health Savings Accounts I. What Are HSAs and Who Can Have Them? What is an HSA? An HSA is a tax-exempt trust or custodial account established exclusively for the purpose of paying qualified medical expenses
Beginning in 2018, the Patient Protection and Affordable Care Act imposes an excise tax on high-cost health plans. In addition to being a way to raise revenue for the government, the reason for this provision
ALL NEW MATTER.01 Scope. This chapter applies to: A. Each carrier that offers a medically underwritten health benefit plan in the nongroup market in the State; and B. Each SAAC carrier..02 Definitions.
Proposed Rule: Health Insurance Providers Fee Description: This document contains proposed regulations that provide guidance on the annual fee imposed on covered entities engaged in the business of providing
The Honorable Orrin G. Hatch, Chairman, Chairman Senate Committee on Finance House Committee on Ways and Means 219 Dirksen Senate Office Building 1102 Longworth House Office Building Washington, DC 20510
from Human Resource Services IRS gives first glimpse of rules on ACA excise tax on high cost health plans and asks for input February 27, 2015 In brief The IRS has issued a Notice laying out some initial
Health Care Reform: W2 Reporting Requirement The Affordable Care Act requires employers to report the cost of coverage under an employersponsored group health plan. Reporting the cost of health care coverage
Health savings account Q&As What are HSAs and who can have them? 1. What is a Health Savings Account (HSA) and how does it work? An HSA is a tax-advantaged account established to pay for qualified medical
Health Law Update: Health Savings Account Provisions in the Medicare Prescription Drug Improvement and Modernization Act of 2003 This Update summarizes the provisions of the Medicare Prescription Drug,
Further Guidance on the Application of the Group Health Plan Market Reform Provisions of the Affordable Care Act to Employer-Provided Health Coverage and on Certain Other Affordable Care Act Provisions
Guidance on the Application of Code 4980D to Certain Types of Health Coverage Reimbursement Arrangements Notice 2015-17 I. PURPOSE AND OVERVIEW This notice reiterates the conclusion in previous guidance
In June 2014, the Board of Directors of the American Benefits Council (the Council) approved a long-term public policy strategic plan, A 2020 Vision: Flexibility and the Future of Employee Benefits. It
Transitional Reinsurance Program Fees Submission of Annual Enrollment and Contributions The Patient Protection and Affordable Care Act (Affordable Care Act) fundamentally changed the way health insurance
Revised December 2014 Health FSA-HRA-HSA Comparison Chart Health Flexible Spending Internal Revenue Code source Section 125 (cafeteria plans) applies to an arrangement where employees have a choice among
Part III Administrative, Procedural, and Miscellaneous Health Insurance Providers Fee; Procedural and Administrative Guidance Notice 2016-14 SECTION 1. PURPOSE This notice provides guidance for fee year
Brought to you by The Insurance Exchange Affordable Care Act (ACA) Violations Penalties and Excise Taxes The Affordable Care Act (ACA) includes numerous reforms for group health plans and creates new compliance
HB3004 Enrolled LRB9200745JSpc 1 AN ACT to amend the Comprehensive Health Insurance Plan 2 Act by changing Sections 2 and 15. 3 Be it enacted by the People of the State of Illinois, 4 represented in the
COBRA AND OTHER HEALTH CARE ISSUES By Debbie Dees Phelps Dunbar LLP 111 East Capitol Street, Suite 600 Post Office Box 23066 Jackson, Mississippi 39225-3066 Telephone: (601) 360-9334 Facsimile: (601) 360-9777
The Small Business Health Care Tax Credit Kit About the Small Business Health Care Tax Credit Kit This Kit is designed to assist small employers in understanding the Small Business Health Care Tax Credit,
Part III - Administrative, Procedural, and Miscellaneous Health Reimbursement Arrangements Notice 2002-45 PURPOSE This notice provides basic information about a type of employer-provided health reimbursement
Quality health plans & benefits Healthier living Financial well-being Intelligent solutions Understanding how the health insurance providers fee and transitional reinsurance contribution will affect you
High Cost Insurance Plans Excise Tax Summary: Levies an excise tax of 40 percent on insurance companies and plan administrators for any health coverage plan that is above the threshold of $10,200 for single
Health Care Reform 2013 & 2014 Planning Employers should review the fast-approaching 2013 and 2014 health care reform requirements. State Exchanges will be opening enrollment as soon as October 1, 2013
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION The Affordable Care Act: Processes Have Been Implemented to Administer the Patient-Centered Outcomes Research Fee, but Controls Need Improvement to Ensure
SEPTEMBER 2015 Looking Under the Hood of the Cadillac Tax Author, Laura Westfall, New York +1 212 556 2263, firstname.lastname@example.org The Patient Protection and Affordable Care Act ( ACA ) s 40% excise tax on
Form W-2 Health Coverage Reporting Requirements - Updated August 2015 The Affordable Care Act (ACA) requires employers to report the aggregate cost of employer-sponsored group health plan coverage on their
Health Savings Accounts: Common Questions and Their Answers I. General HSAs II. Qualified High-Deductible Health Plan HDHPs III. Contributions to an HSA Distributions BlueAccount I. General HSAs I.1 What
333 West 34th Street New York, NY 10001-2402 T 212.251.5000 F 212.251.5490 www.segalco.com MEMORANDUM To: From: Lynette Metz Lawrence Singer, Karen Johnson Date: July 19, 2013 Re: Affordable Care Act (ACA)
Health care reform at-a-glance August 2014 Employer mandate Shared responsibility payment for failing to offer coverage to at least 95%* of all fulltime employees (FTE) and children if any FTE gets subsidy
Employers Defined: Tax Credit Small employer definition for Tax Credit - number of full-time employees Fewer than 25 full-time employees with average wages of less than $50,000 Divide total hours for which
North Carolina Statutes Health Insurance Portability and Accountability PART A. GROUP MARKET REFORMS SUBPART 1. PORTABILITY, ACCESS, AND RENEWABILITY REQUIREMENTS 58-68-25. Definitions; excepted benefits;
STATE OF OKLAHOMA 2nd Session of the 49th Legislature (2004) HOUSE BILL HB2563: Greenwood AS INTRODUCED An Act relating to revenue and taxation; creating the Health Savings Account Act; defining terms;
Part III - Administrative, Procedural, and Miscellaneous Section 45R Tax Credit for Employee Health Insurance Expenses of Small Employers Notice 2010-44 I. PURPOSE AND BACKGROUND Section 45R of the Internal
2013 Small Employer Health Care Tax Credit 1 Is Your Church or Organization Eligible? This announcement contains important information about the Small Employer Health Care Tax Credit to help you determine
Keeping up with the new health care reform law Helping you better understand what to expect and when to expect it. 14376CAEENABC 8/10 anthem.com/ca 1 Staying up to date Here s a timeline of what you can
Attorneys at Law Friday, January 29, 2016 IRS NOTICE 2015-87: ADDITIONAL GUIDANCE ON HRAS, ACA REPORTING, HEALTH FSA CARRYOVERS AND MORE By: Gabriel S. Marinaro, Esq. In December of 2015, the IRS issued
Brought to you by Hickok & Boardman HR Intelligence Employer Reporting of Health Coverage Code Sections 6055 & 6056 The Affordable Care Act (ACA) created new reporting requirements under Internal Revenue
Under ACA rules, all employers that offer self-insured health plans must report new, detailed information on every individual covered under their health plan. There are reporting requirements for self-insured
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight 200 Independence Avenue SW Washington, DC 20201 Date: July 17, 2014
Introduction ACAP Guide to ACA Fees and Taxes for Health Insurers Since being signed into law in March of 2010, the Patient Protection and Affordable Care Act (ACA) has introduced a wide range of health
MARCH 2015 IRS Clarifies That After-Tax HRAs and Other Individual Health Insurance Payment Arrangements Generally Violate the Affordable Care Act; Limited Transition Relief Available Author, Laura Westfall,
JANUARY2011 National Health Insurance Reform Impact Year by Year With the passage of National Health Insurance Reform it is crucial that employers and plan sponsors have clear information about the impact
/Financial and Other Benefits Concerns for All Employers (updated May 2, 2014) Lisa L. Carlson, J.D., Area Senior Vice President, Compliance Counsel Gallagher Benefit Services, Inc. While most healthcare
March 6, 2014 Treasury, IRS Release Final Rules on Employer Information Reporting Requirements Under Health Care Law The Department of the Treasury and the IRS late yesterday (March 6, 2014) released long
[4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 57 [REG-118315-12] RIN 1545-BL20 Health Insurance Providers Fee AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice
Section 125 - Cafeteria Plans Health flexible spending arrangements not subject to $2,500 limit on salary reduction contributions for plan years beginning before 2013 and comments requested on potential
December 2013 Employer mandate Play or pay penalty for failing to offer coverage to at least 95% of all full-time employees (FTE) and children if any FTE gets subsidy in exchange $2,000 (indexed) times
Part III Administrative, Procedural, and Miscellaneous Section 105 - Amounts Received Under Accident and Health Plans (Also Sections 106-Contributions by Employers to Accident and Health Plans, 162(l)-
IRS Notice 2015-87: A Grab Bag of ACA, HRA and FSA Guidance CALLAN CARTER Please note: This article was updated on March 8, 2016 In a welcome set of Questions and Answers, IRS Notice 2015-87 (the Notice
IC 27-8-15 Chapter 15. Small Employer Group Health Insurance IC 27-8-15-0.1 Application of certain amendments to chapter Sec. 0.1. The following amendments to this chapter apply as follows: (1) The addition
Weyrich, Cronin & Sorra, Chartered Health Insurance Reporting Requirements Date: 9/17/2014 The Affordable Care Act (ACA) brought many changes into the law, taking effect over a period of years. Among these
Revised January 2012 Notice 2012-9 provides guidance on W-2 reporting requirement IRS Issues New Guidance on Health Care Reform s The Internal Revenue Service (IRS) recently issued IRS Notice 2012-9, which
Expatriate Health Coverage Clarification Act of 2014, Interim Guidance Notice 2015-43 I. PURPOSE This notice provides interim guidance on the application of certain provisions of the Affordable Care Act
Frequently Asked Questions Affordable Care Act (ACA) Taxes: Reinsurance Tax and Insurer Tax May 16, 2013 Background: One of the goals of the Affordable Care Act (ACA) is to ensure that everyone involved
EmPowerHR Legislative Brief: HEALTH SAVINGS ACCOUNT (HSA) ELIGIBILITY Many employers offer high deductible health plans (HDHPs) to control premium costs, and pair this coverage with health savings accounts
Brought to you by Seubert & Associates Small Employer Health Care Tax Credit: Questions & Answers (Q&A) The Patient Protection and Affordable Care Act (ACA) provides a tax credit to certain small employers
Insurance; health benefits; health care transparency data aggregator; require department of health and human services to establish, require health carriers to submit data, and require release of certain
October 18, 2013 Authors: Kathryn B. Amin, Jon W. Breyfogle, Christine L. Keller, William F. Sweetnam and Brigen L. Winters If you have questions, please contact your regular Groom attorney or any of the
Health Care Reform: A Guide for Self-Funded Plans Key steps to prepare for 2014 Preparing for the future Snapshot of reform (2010-2019) Table of Contents Health Care Reform is Here: Are you ready? 3 Key
Chapter 32a Medical Care Savings Account Act 31A-32a-101 Title and scope. (1) This chapter is known as the "Medical Care Savings Account Act." (a) This chapter applies only to a medical care savings account
Brought to you by Good Neighbor Insurance Self-insured Plans under Health Care Reform The Affordable Care Act (ACA) includes numerous reforms affecting the health coverage that employers provide to their
Selected Employer Provisions in the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 This chart outlines, in depth, selected provisions in the Patient
Brought to you by Cottingham & Butler Self-insured Plans under Health Care Reform The Affordable Care Act (ACA) includes numerous reforms affecting the health coverage that employers provide to their employees.
Another Notice and Request for Comments on the Cadillac Tax On July 30, the Department of the Treasury and Internal Revenue Service (IRS) issued Notice 2015-52. This is the second Notice asking for stakeholder
FREQUENTLY ASKED QUESTIONS (Information obtained from US Treasury HSA website) HSA Basics What is a Health Savings Account ( HSA )? A Health Savings Account is an alternative to traditional health insurance;
Updates to Affordable Care Act: Law, Regulatory Explanation and Analysis, 2014 Chapter 2. Individuals 205. Individual Health Insurance Mandate In December 2013, the Administration announced that individuals
HSAs, HRAs, and FSAs: Health Savings Account Eligibility & Other Account-based Health Plans This information piece is provided by VEBA Service Group, a Division of Gallagher Benefit Services, Inc. (VSG)
Article 68. Health Insurance Portability and Accountability. 58-68-1 through 58-68-20: Repealed by Session Laws 1997-259, s. 1(a). Part A. Group Market Reforms. Subpart 1. Portability, Access, and Renewability
September 23, 2014 If you have questions, please contact your regular Groom attorney or one of the attorneys listed below: Katie Bjornstad Amin email@example.com (202) 861-2604 Christine L. Keller firstname.lastname@example.org
Health Care Reform Act: Who s Paying the Bill? Walter Miller Schwabe, Williamson & Wyatt P.C. 800 Willamette Street, Suite 600 Eugene, OR 97401 (541) 686-3299 email@example.com TABLE OF CONTENTS Page
VOL. 24, NO. 3 AUTUMN 2011 BENEFITS LAW JOURNAL Federal Benefits Developments Congress Repeals Expanded 1099 Reporting and IRS Issues W-2 Reporting Guidance Edward Fensholt and Mark Holloway The federal