The EEOC wellness rules are almost out, but EEOC is wasting no time in bringing suit against employers who allegedly engage in bad behavior with wellness programs. See the link below for more information.
The IRS has commenced specific section 409A examinations of select large employers. For more information, please see the following Legal Alert.
Currently, California requires that insured health plans provide coverage to enrollees no later than following the completion of a 60 day waiting period. This has posed numerous challenges for employers with employees in many states or with self-funded plans and fully insured plans in California who otherwise have complied with the 90-day maximum waiting period permitted under the Affordable Care Act. It has been a challenge, for example, for employers who allow coverage to begin on the...Continue Reading
On Tuesday morning the U.S. Court of Appeals for the District of Columbia Circuit ruled that an IRS rule for a key piece of the 2010 Affordable Care Act is invalid. The ruling invalidates tax credits/subsidies for low income individuals who purchase health insurance coverage on the federally-run exchange (but does not affect credits for those purchasing coverage under a state-run exchange). Later that day, the U.S. Court of Appeals for the Fourth Circuit came to a contrary decision,...Continue Reading
Since the passage of the Affordable Care Act, it has always been a mystery as to how the Affordable Care Act applies in the United States Territories. Particularly, in Puerto Rico where many mainland U.S. corporations have operations, and who has its own separate Tax Code. Late last week, the Centers for Medicare & Medicaid Services issued letters to the insurance commissioners of the United States Territories (Puerto Rico, the Virgin Islands, Guam, American Samoa and Northern Mariana...Continue Reading