2014

CMS Issues Guidance Related to COBRA Coverage and Exchange Eligibility

COBRA Compliance and Regulatory

On April 21, 2014, CMS issued guidance, in the form of a frequently asked question (FAQ), clarifying how COBRA coverage impacts an individual's eligibility to enroll in the exchange and to receive a premium tax credit. As background, the open enrollment period for almost all exchanges ended March 31, 2014. Individuals may only enroll in the exchange midyear if they qualify for a special enrollment period due to a qualifying event. The FAQ clarifies that during the open enrollment period for the exchange, an individual who has voluntarily terminated his/her COBRA coverage (i.e., COBRA coverage has not been exhausted) will be eligible to enroll in a qualified health plan through the exchange.

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SB1339 Bay Area Commuter Benefits is Official

Transit Transit and Parking Section 132

San Francisco recently took a major step in helping both its hard-working citizens and the environment. On March 26, 2014, the SB 1339 Bay Area Commuter Benefits Program became official. Now the Bay Area Air District and the Metropolitan Transportation Commission (MTC) will be working together with their regional Bay Area commuter policy, which mandates that all employers with 50 or more full-time employees, offer commuter benefits to both full-time workers and those that work at least 20 hours a week. Employers have until September 30, 2014, to comply with the SB 1339 Bay Area Commuter Benefits Program.

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San Francisco Bay Area Passes Regional Commuter Benefit Legislation

Transit and Parking Section 132

Achieving lower commuting costs and climate protection without raising taxes.

March 26, 2014 - (Boston, MA) Today, the Metropolitan Transportation Commission approved Regulation 14 Rule 1 of the Bay Area Air Quality Management District, which requires a commuter benefit program to be in place for all employers that have 50 or more full-time employees in the nine-county Bay Area. This regulation is a result of SB 1339, which was signed into law by Governor Brown, requiring a pilot project to be in effect until January 2017. According to the text of the bill, SB 1339, the state believes that by requiring large employers to offer commuter benefit programs, it will encourage greater use of mass transit and vanpools. For those employees who already commute to work using mass transit, it will offer them significant tax savings. Participating employers will also reduce their tax burden. Employers will have until September 30, 2014, to comply with this regulation.

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Treasury Department Delays ACA Employer Mandate for Certain Employers

Compliance and Regulatory

Treasury Department Delays Affordable Care Act (ACA) Employer Mandate Until 2016 for Employers with 50-99 Employees that Do Not Yet Provide Affordable Insurance to Full Time Workers

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