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ACA Affordability Contribution Rate Set at 9.78% for 2020

July 26, 2019

New Figure Marks Decrease from 2019 Under the employer shared responsibility (“pay or play”) provisions of the Affordable Care Act, applicable large employers—generally those who have 50 or more full-time employees (including full-time equivalent employees)—may be subject to a penalty if they do not offer affordable coverage that provides minimum value to their full-time employees …

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Reminder: PCORI Fees Due July 31

July 15, 2019

Fees Apply to Employers Sponsoring Certain Self-Insured Plans As a reminder, employers that sponsor certain self-insured health plans are responsible for Patient-Centered Outcomes Research Institute (PCORI) fees. Fees for plan years that ended in 2018 are due July 31, 2019. Employers must report and pay the required PCORI fees annually via IRS Form 720. For …

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HHS Proposes Rolling Back ACA Nondiscrimination Regulations

May 31, 2019

Rule Would Revise Interpretation of Section 1557 The Department of Health and Human Services (HHS) has released a proposed rule (PDF) that would eliminate portions of its existing regulations under Section 1557 of the Affordable Care Act (ACA), which addresses nondiscrimination in certain health care programs. The new rule, if finalized, would (among other things) …

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DOL Issues Additional Guidance on Scope of Enforcement Relief for AHPs

May 20, 2019

Q&As Provide More Clarity for Employers after Court Decision The U.S. Department of Labor (DOL) has issued questions and answers (PDF) on the scope of its enforcement relief for association health plans (AHPs), described in an earlier policy statement. The guidance comes in the wake of a federal court decision striking down part of a …

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Reminder: PCORI Fees Due July 31

May 14, 2019

Fees Apply to Employers Sponsoring Certain Self-Insured Plans As a reminder, employers that sponsor certain self-insured health plans are responsible for Patient-Centered Outcomes Research Institute (PCORI) fees. Fees for plan years that ended in 2018 are due July 31, 2019. Employers must report and pay the required PCORI fees annually via IRS Form 720. For …

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New Jersey Updates Information on Health Care Reporting Requirement

May 13, 2019

Employers Will File Forms 1094 and 1095 through State W-2 Filing System in 2020 New Jersey recently updated its website information on employer health coverage reporting. As part of the state’s individual health insurance mandate, starting with tax year 2019, employers must provide New Jersey taxpayers and the state with the same 1094 and 1095 …

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AHP Coverage Can Generally Be Maintained Through Plan Year or Term

May 7, 2019

DOL Appeals Court Decision, Issues Policy Statement The U.S. Department of Labor (DOL) has appealed a March federal court decision (PDF) striking down parts of the DOL rule on association health plans (AHPs). The rule had expanded employers’ ability to join in AHPs to purchase health coverage. The agency also issued a statement that employers …

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2020 Cost-Sharing Limits for Most Group Health Plans Released

April 23, 2019

HHS Issues Key Rule for 2020 A new rule (PDF) from the U.S. Department of Health and Human Services (HHS) addresses, among other things, the requirement under the Affordable Care Act that non-grandfathered group health plans limit annual out-of-pocket cost-sharing for coverage of essential health benefits under the plan. Under the rule, these out-of-pocket expenses …

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Small Businesses May Be Able to Keep Existing Non-ACA Compliant Health Coverage Through 2020

April 1, 2019

Policies Renewed Under Extended Non-Enforcement Policy Must Comply by January 1, 2021 A previously extended non-enforcement policy which allows health insurance issuers, at their option, to continue group coverage that would otherwise be terminated or cancelled has been further extended to policy years beginning on or before October 1, 2020, provided that all policies come …

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Court Strikes Down Association Health Plan Rule

March 29, 2019

DOL Rule Called ‘End-Run’ Around Affordable Care Act A federal judge has ruled that two parts of the Department of Labor (DOL) rule expanding employers’ ability to join in association health plans (AHPs) violate ERISA. AHPs are group health plans sponsored by a group of employers. In June 2018, the DOL issued a rule allowing …

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