The Federal District Court for the Western District of Washington has ruled, in C.P. vs. Blue Cross Blue Shield of Illinois, that an insurer acting as a third party administrator (“TPA”) is covered by the nondiscrimination rules of Section 1557 of the Affordable Care...
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Affordable Care Act
IRS Requires Most Employee Benefit Plans to File Forms Electronically
The IRS has issued final regulations that will require almost all employee benefit plan filings to be made electronically. Background. Generally, Applicable Large Employers are required to file Forms 1094 and 1095 with the IRS to report their compliance with the ACA’s...
Rule Proposes Removing Moral Exemption to Contraception Mandate
Rule Proposes Removing Moral Exemption to Contraception Mandate - Marcia Wagner, SHRM, January 30, 2023 (PDF)
2024 ACA Out-of-Pocket Limits
The U.S. Department of Health and Human Services (HHS) has announced the inflation-adjusted maximum out-of-pocket (OOP) limits that will apply to non-grandfathered plans for plan years beginning in 2024. The OOP limit includes the plan’s deductible and cost sharing...
Federal Agencies Issue Group Health Plan Guidance
By Roberta Watson, Barry Salkin and Dannae Delano On December 23, 2022, new guidance applicable to group health plans was issued by federal agencies, as described more fully below. The Center for Medicare and Medicaid Services issued updated fee guidance in...
IRS Finalizes Delayed Effective Dates for ACA Filing Requirements
In past years, the IRS has extended the deadlines for employer and group health plan Affordable Care Act (“ACA”) reporting. In lieu of the deadline extensions, the IRS has now issued final regulations that provide for a permanent, automatic extension of the deadline...
Mental Health Parity Rules and Requirements for Plan Sponsors and Administrators
Mental Health Parity Rules and Requirements for Plan Sponsors and Administrators - Roberta Casper Watson, panelist, Strafford live CLE webinar, January 4, 2023, 1:00 - 2:30 PM (EST) - Click here for details
IRS Announces Expansion of Change in Status Rules for Cafeteria Plans
One of the basic rules under which cafeteria plans operate is that elections are irrevocable except in certain limited circumstances. Further, even when those limited circumstances apply, the change in election must be consistent with the change in status. Legislative...
New IRS Regulations Resolve “Family Glitch” Issue
The IRS has issued final regulations amending the Affordable Care Act (“ACA”) rules regarding eligibility for the law’s premium tax credit (“PTC”). The new rules provide that the “affordability” of employer-sponsored coverage for employees’ family members is based on...
Federal Court Finds Key Part of ACA’s Preventive Service Mandate Unconstitutional
A Texas federal district court, in Braidwood Management, Inc. v. Becerra, has held that the Affordable Care Act’s (“ACA’s”) requirement that most group health plans and health insurers cover certain recommended preventive services without cost-sharing violates the...