compliance
August 30, 2021
Departments Defer Transparency and Disclosure Rule Enforcement, Provide FAQ Guidance
On August 20, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury (collectively, the Departments), issued FAQ guidance regarding provisions of the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations Act, 2021 (CAA). ...
August 19, 2021
Compliance Recap | July 2021
July 2021 was a quiet month in the benefits industry, largely due to the summer vacation season and the July 4th Independence Day holiday. Importantly, however, the U.S. Departments of Health and Human Services, Labor, and Treasury, along with the Office of Personnel Management (collectively, ...
July 27, 2021
ARPA COBRA Premium Assistance IRS Q&A Guidance
On July 26, 2021, the Internal Revenue Service (IRS) released Notice 2021-46 (Notice) to clarify lingering questions employer plan sponsors and other interested parties have been asking since the American Rescue Plan Act of 2021 (ARPA) became law this past March. The Notice supplements prior ...
July 26, 2021
No Surprise Billing Interim Final Regulations Part 2
On July 1, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury, along with the Office of Personnel Management (collectively, the Departments), issued an interim final rule (IFR) to explain provisions of the No Surprises Act (the Act) that passed as part of sweeping ...
July 22, 2021
IRS Issues Draft Form 1095-C
The Internal Revenue Service (IRS) recently issued the 2021 Draft Form 1095-C, which is required to be filed with the IRS by applicable large employers (ALEs), to report the offer of health coverage to employees. New Codes An ALE that offers an individual coverage health reimbursement ...
July 13, 2021
Compliance Recap | June 2021
June 2021 was not a busy month in the benefits industry, largely due to the summer vacation season and the Independence Day holiday. Importantly, however, the U.S. Supreme Court upheld the constitutionality of the Patient Protection and Affordable Care Act (ACA). Additionally, the IRS unveiled ...
July 9, 2021
No Surprise Billing Interim Final Regulations Part 1
On July 1, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury, along with the Office of Personnel Management (collectively, the Departments), issued an interim final rule (IFR) to explain provisions of the No Surprises Act (the Act) that passed as part of sweeping ...
June 29, 2021
DOL Requires Disclosure of Audio Recordings Under ERISA Claims Procedure
The Department of Labor (DOL) recently issued Information Letter 06-14-2021 in which the DOL opined that audio recordings of a conversation between a participant and plan representative, and transcripts of the recordings, are subject to disclosure during the claims adjudication process under ...
June 24, 2021
Transitional Relief May Be Transitioning Out
Employers providing health coverage are required in many cases to report annual information returns and statements regarding employee and dependent coverage to the IRS. Notice 2020-76 provided relief from penalties for certain aspects of the 2020 information-reporting requirements as it relates ...
June 18, 2021
IRS Tool for Advance Child Tax Credit
On June 14, 2021, the IRS issued a news release which unveiled an online Non-filer Sign-up tool designed to help eligible families who don’t normally file tax returns register for the monthly Advance Child Tax Credit payments, scheduled to begin July 15. The tool is also designed to help ...
