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The IRS has explained how employees enrolled in Medicare affect an employers' liability under the Affordable Care Act's ("ACA's") employer shared responsibility penalties. Under the ACA, employers with 50 or more full-time equivalent employees are subject to one of...
On June 30, 2016, the U.S. Department of Labor published an interim final rule to adjust for inflation the civil monetary penalties it is charged with enforcing. Current law requires Federal agencies, including the Department of Labor (the "DOL"), to adjust their...
The IRS has confirmed that ACA information return filers that failed to meet the June 30, 2016 deadline for electronically submitting Forms 1094-C (and related Forms 1095-C) via the IRS's ACA Information Return system ("AIR system") will not be penalized for filing...
The EEOC has released a sample notice and corresponding Q&As to explain to employers the notice requirements applicable to wellness programs that include disability-related inquiries or medical examinations. Background. Employers may sponsor wellness programs and...
IRS, DOL, and HHS have issued proposed regulations on expatriate health plans, expatriate health issuers and qualified expatriates under the Expatriate Health Coverage Clarification Act of 2014 ("EHCCA"). Background. The ACA made various changes to federal health...
The Equal Employment Opportunity Commission ("EEOC") has issued two sets of final regulations that provide guidance on how employer-sponsored wellness programs that require employees to answer disability-related questions or undergo medical examinations can comply...
The Internal Revenue Service has released Revenue Procedure 2016-24 to implement index adjustments in 2017 for certain Affordable Care Act ("ACA") contribution percentages. Background. Under ACA, contribution percentages are used to determine: (i) whether an...
DOL has released a new FMLA Guide along with a new General FMLA Notice to help employers administer the FMLA requirements. FMLA Guide. DOL says that its new FMLA Guide, "The Employer's Guide to the Family and Medical Leave Act", is designed to provide essential...
The Wagner Law Group requested a Private Letter Ruling ("PLR") on behalf of a client ("Taxpayer") that terminated its defined benefit pension plan ("DB Plan") even though the DB Plan had a yet-to-be determined contingent liability ("Liability") related to an...
Almost a year after being proposed and after public hearings and thousands of comment letters, the U.S. Department of Labor ("DOL") has finalized its regulation redefining and broadening the meaning of fiduciary investment advice rendered to retirement plans and IRAs....