compliance

compliance

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 ...

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 ...

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 ...

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 ...

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 ...

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 ...

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 ...

Supreme Court Upholds the Affordable Care Act

On June 17, 2021, the U.S. Supreme Court upheld the constitutionality of the Patient Protection and Affordable Care Act (ACA) by a 7-to-2 vote. The Court heard oral arguments in the case, California v. Texas, on November 10, 2020, which was a consolidation of 20 cases filed by state attorneys ...

Compliance Reminder | PCORI Fee Notice

This is a reminder that the Patient-Centered Outcomes Research Institute (PCORI) fee imposed by the Patient Protection and Affordable Care Act (PPACA) on your health plan is due by 07/31/21.  The fee is due by July 31st of the year following the end of the plan year.  The following chart will ...

Compliance Recap | May 2021

May 2021 was a somewhat busy month in the benefits industry. The absence of a significant of amount of agency guidance during the summer months is to be expected. However, the IRS finally issued guidance on the temporary 100% COBRA subsidy mandated by the American Plan Rescue Act of 2021 (the ...

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