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Cadillac Tax Would Have a Deep Impact on Employers

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Category: ACA, Compliance and Regulatory,

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Cadillac Tax Would Have a Deep Impact on Employers

BusinessWest on March 8, 2016 in Banking and Financial Services

New Rules of the Road

By BOB CUMMINGS

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Although many provisions of the Affordable Care Act (ACA) have already been implemented, a few major ones are still to come. None are as far-reaching as the proposed ‘Cadillac tax’ on employer-sponsored health benefits.

Originally scheduled to take effect in 2018, the Cadillac-tax implementation was recently pushed off to 2020. If implemented, the IRS will impose a 40%, non-deductible excise tax on certain employer-sponsored health benefits that exceed a dollar threshold of $10,200 for an individual and $25,500 for a family. Health-insurance companies and self-insured plan sponsors will have to pay the tax on excess dollar amounts for benefits provided above this threshold. After 2020, the limits are to be adjusted for future changes in the consumer price index.

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Getting a Grasp on the New Health-benefits Reporting Rules

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Category: ACA, Compliance and Regulatory,

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Getting a Grasp on the New Health-benefits Reporting Rules

BusinessWest on January 12, 2016 in Banking and Financial Services

Delayed Reaction

By BOB CUMMINGS

tl_files/content/about/Bios/RCummings_Head.jpgFor many employers, their first challenge with the Affordable Care Act (ACA) may be compliance with the new reporting requirements.

Under the ACA, the Internal Revenue Code added IRS Section 6056, which requires ‘applicable large employers’ to file information returns with the IRS and provide statements to their full-time employees about the health-insurance coverage that the employer offered. Under the terms of the ACA, an applicable large employer generally means an employer that had 50 or more full-time employees (including full-time equivalent employees) in the preceding calendar year.

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Getting a Grasp on the New Health-benefits Reporting Rules

(comments: 0)
Category: ACA, Compliance and Regulatory,

tl_files/content/blog/2016/BusinessWest.png

Getting a Grasp on the New Health-benefits Reporting Rules

BusinessWest on January 12, 2016 in Banking and Financial Services

Delayed Reaction

By BOB CUMMINGS

tl_files/content/about/Bios/RCummings_Head.jpgFor many employers, their first challenge with the Affordable Care Act (ACA) may be compliance with the new reporting requirements.

Under the ACA, the Internal Revenue Code added IRS Section 6056, which requires ‘applicable large employers’ to file information returns with the IRS and provide statements to their full-time employees about the health-insurance coverage that the employer offered. Under the terms of the ACA, an applicable large employer generally means an employer that had 50 or more full-time employees (including full-time equivalent employees) in the preceding calendar year.

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ACA Reporting and HRAs

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Category: ACA, Health Reimbursement Arrangements, HRA, IRS,

Section 6056 Update

Good news!  The IRS has changed their position on both of these issues!
 
We just received final 2015 versions of the instructions for Forms 1094-B, 1095-B, 1094-C, and 1095-C.
 
Reporting HRA Coverage
In the instructions for Forms 1094-B and 1095-B, the IRS states:

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Group Health Plans that Fail to Cover In-Patient Hospitalization Services

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Category: ACA, Compliance and Regulatory, HHS,

Notice 2014-69

I.  PURPOSE AND OVERVIEW

The Department of Health and Human Services (HHS) and the Department of the Treasury (including the Internal Revenue Service) (collectively, the Departments) have become aware that certain group health plan benefit designs that do not provide coverage for in-patient hospitalization services are being promoted to employers.  A plan that fails to provide substantial coverage for these services would fail to offer fundamental benefits that are nearly universally covered, and historically have been considered integral to coverage, under typical employer-sponsored group health plans. Promoters of these plans contend that the plans satisfy minimum value within the meaning of the Affordable Care Act (including section 36B(c)(2)(C)(ii)of the Internal Revenue Code (Code) and final HHS regulations under section1302(d)(2)(C) of the Affordable Care Act (referred to in this notice as minimum value or MV)), as determined through use of the on-line MV Calculator referred to in final HHS regulations and proposed Treasury regulations.

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Premium Tax Credits at Risk After Circuit Split

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Category: ACA, IRS, PPACA,

Two federal appeals courts issued conflicting rulings on a key provision of the Patient Protection and Affordable Care Act (PPACA) relating to the availability of premium tax credits and cost-sharing subsidies on the federally facilitated exchanges. First, the U.S. Court of Appeals for the D.C. Circuit, in Halbig v. Burwell, overturned this provision, stating that PPACA does not authorize the Internal Revenue Service (IRS) to provide premium tax credits and cost-sharing subsidies for insurance purchased on the federally facilitated exchanges (as the law does for insurance purchased on state-established exchanges). Shortly thereafter, the U.S. Court of Appeals for the Fourth Circuit, in King v. Burwell, upheld the same PPACA provision, stating that PPACA does authorize the IRS to provide premium tax credits and cost-sharing subsidies on federally facilitated exchanges. Parties in both cases plan to appeal the rulings, and the cases appear to be headed to the U.S. Supreme Court, particularly with the circuit split.

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