Archive by category: ComplianceReturn
The IRS recently issued draft versions of Forms 1094-B, 1094-C, 1095-B and 1095-C information returns for the 2017 tax year. The Affordable Care Act requires coverage providers to use Forms 1094-B and 1095-B to report health plan enrollment and requires applicable large employers to use Forms 1094-C and 1095-C to report about employer shared responsibility. The Forms also provide relevant information about individual shared responsibility and premium tax credits.
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Categories: Health Care Reform, Compliance, Health Care in General | Tags: Affordable Care Act , ACA , 1094-B , 1095-B , 1094-C , 1095-C , information letter , IRS , Internal Revenue Service , draft , ALE , applicable large employer , Office of Chief Counsel , employer shared responsibility , individual mandate
Real estate giant Cushman & Wakefield Inc. is facing a class-action lawsuit from qualified beneficiaries alleging that the COBRA election notices they received were deficient and violated the COBRA regulations. This case provides an important reminder to employers and plan administrators that COBRA election notices must not only be timely sent to qualified beneficiaries, but the content of the notices must also contain all the requirements mandated by the COBRA regulations.
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Categories: Compliance | Tags: COBRA , Consolidated Omnibus Budget Reconciliation Act , Cushman , Cushman & Wakefield , Cushman and Wakefield , notice , department of labor , class action , lawsuit , court , case , legal
HSAs are growing in popularity. So exactly who is eligible to establish an HSA account and make an HSA contribution or have a contribution made on his/her behalf (e.g., by an employer)?
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Categories: Benefits in General, Compliance | Tags: HSA , FSA , Health FSA , Disqualifying Coverage , Permitted Coverage , Health Savings Account

Repeal and Replace ACA-Employer View

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The International Foundation of Employee Benefit Plans (IFEBP) this month released the results from a survey that asked 727 employers their views on the Affordable Care Act (ACA) and repeal-and-replace efforts.
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Categories: Health Care Reform, Compliance | Tags: ACA , Repeal and replace , IFEBP , Cadillac tax , Employer mandate , Health FSA , HSA
On June 9, 2017, new Department of Labor regulations (“Fiduciary Rules”) took effect which expand the categories of persons who may now be considered plan “fiduciaries” under ERISA and the Internal Revenue Code. The new Fiduciary Rules broaden the definition of plan “fiduciary” to include persons who provide investment advice to account holders of Individual Retirement Accounts and Health Savings Accounts (“HSAs”). As such, the new Fiduciary Rules have important implications for HSA ser...
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Categories: Benefits in General, Compliance | Tags: HSA , Health Savings Accounts , fiduciary rules , fiduciary , service provider , employer , TPA , third-party administrator , third party administrator , invest , advice , recommendation

Form 5500 Deadlines and Extensions

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Employers that are subject to ERISA that sponsor health and welfare plans subject to ERISA (i.e. health insurance, dental insurance, life insurance, disability insurance, Health Reimbursement Arrangement (HRA), and Health Care Flexible Spending Account (FSA) portion of a cafeteria plan, etc.) may have a Form 5500 obligation.
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Categories: Benefits in General, Compliance | Tags: Form 5500 , IRS , Form 5558 , DOL , DFVC

DOL Updates Various Model Notices

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The Department of Labor (DOL) has extended the effective date of various notices.
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Categories: Health Care Reform, Compliance, Health Care in General | Tags: CHIPRA , DOL , COBRA , Exchange , Model Notice
The IRS recently released an information letter clarifying the definition of a high deductible health plan (HDHP) for purposes of HSA eligibility. In the letter, the IRS explained that to qualify as an HDHP, a medical insurance plan (i) must satisfy certain minimum annual deductible and maximum out-of-pocket expense requirements and (ii) cannot provide any benefits below the minimum annual deductible, other than preventive care benefits.
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Categories: Health Care Reform, Compliance, Health Care in General | Tags: HSA , HDHP , IRS , health savings account , high deductible health plan , Internal Revenue Service , information letter
The DOL recently issued a Field Assistance Bulletin and FAQ guidance confirming that, after a delay from April 10, 2017, the new fiduciary rules and related prohibited transaction exemptions will become effective on June 9, 2017, with phased implementation through January 1, 2018.
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Categories: Compliance | Tags: DOL , Department of Labor , Field Assistance Bulletin , FAQ , fiduciary rules , fiduciary
The IRS has released 2018 key indexing adjustments used under the Affordable Care Act (ACA). This revenue procedure is effective for taxable years and plan years beginning after December 31, 2017.
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Categories: Benefits in General, Health Care Reform, Compliance | Tags: ACA , Affordability , IRS , Tax Credits
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