Posts Categorized: Affordable Care Act

If You Have Less than 50 Employees, Read This

in Affordable Care Act, Health Benefits

You may not yet have heard about a new type of health plan arrangement created in December 2016 for small employers – the “QSEHRA”.  Many employers, particularly small employers, were adversely affected by a change in the law prohibiting employers from reimbursing employees for the cost of their individual health policies.  Under this new law, Qualified Small Employers can adopt a Health Reimbursement Arrangement that complies with the rules set out in Internal Revenue Code Section 9831(d).  These new arrangements are available only to employers with less than 50 full-time employees and full-time equivalent employees who offer no health plan… Continue Reading

IRS Extends ACA Reporting Deadline

in Affordable Care Act, Tax Issues

This afternoon the Internal Revenue Service issued IRS Notice 2016-70 extending the distribution due date for ACA reporting purposes. Specifically, the notice extends by 30 days the due date for distributing the 2016 Form 1095-B and the 2016 Form 1095-C, from January 31, 2017, to March 2, 2017.  Further, the Service has determined that no extension is needed for filing such forms with the Service.  Therefore, the due date for filing with the Service the 2016 Forms 1094-B, 1095-B, 1094-C, or 1095-C remains February 28, 2017, if not filing electronically, or March 31, 2017, if filing electronically. The notice also… Continue Reading

Required Reading – New Instructions for ACA Reporting

in Affordable Care Act, Health Benefits, Tax Issues

Unlike the forms for the 2015 calendar year, the 2016 Forms 1095-C must be provided to employees by January 31 and must be submitted to the IRS electronically by March 31 (for those with under 250 forms submitting on paper, the deadline is February 28).  Newly revised forms and instructions for this purpose have just been released.  Although the forms have not changed much, the instructions have changed significantly.  The penalties for failing to file a correct form with the IRS or an individual is $260 for each; certain caps and exceptions apply. Even those who mastered the 2015 instructions… Continue Reading

ACA Reporting – Multiple Coverage and Requesting SSNs

in Affordable Care Act, Health Benefits

Newly proposed IRS regulations seek to clarify certain aspects of reporting of minimum essential coverage by employers and issuers under Code Section 6055.  Here, we focus on proposals that impact employer reporting (Part III of Form 1095-C).  These rules do not affect Parts I and II of Form 1095-C. No duplicative reporting required:  Because the prior rules regarding reporting of duplicative minimum essential coverage (MEC) were confusing, these proposed rules clarify that: If an individual is covered by more than one plan providing MEC provided by the same reporting entity (the plan sponsor, for a single-employer self-funded plan), reporting is… Continue Reading

Proposed Rules for Expatriate Health Plan and Certain Excepted Benefits under ACA

in Affordable Care Act, Health Benefits

Newly proposed regulations address the application of the Affordable Care Act to expatriate health plans (whether insured or self-insured), travel insurance and certain other excepted benefits, effective for plan years beginning on and after January 1, 2017.  These regulations include proposed conforming amendments relating to the Expatriate Health Coverage Clarification Act of 2014 (EHCCA) which generally exempts expatriate health plans from many of the ACA requirements.  The proposed rules mainly reflect prior guidance as well as the requirements of EHCCA. It is important to remember that expatriates may still be subject to the individual mandate (but these plans may qualify… Continue Reading