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ICHRA Subject to ACA Reporting

An Individual Coverage Health Reimbursement Arrangement (“ICHRA”) became an available option for employers beginning January 1, 2020. An ICHRA is available to employers of any size to reimburse employees for individual health care coverage (i.e., health coverage bought through the Marketplace, private insurance, or Medicare Part A and B or C coverage), subject to certain […]
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Affordable Care Act Reporting for 2020

Employers face a great deal of challenges in 2020 related to COVID-19, including lock down orders, supply chain disruptions, and virtually unprecedented economic uncertainty.  The patchwork of state and federal responses to assist business, ranging from forgivable loans to deadline relief, does not currently extend to relief from the annual information reporting requirement under the […]
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ICHRAs and ACA Affordability Rules

Effective January 1, 2020, many employers will have the option of offering individual coverage HRAs (“ICHRAs”) to reimburse employees for individual health insurance coverage.  ICHRAs allow employers to satisfy the Affordable Care Act (“ACA”) mandate to offer health insurance to full-time employees in a manner distinct from sponsoring traditional insured or self-funded group health coverage.  […]
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Proposed Regulations for HRAs

On October 23, 2018, the Departments of Treasury, Labor, and Health and Human Services released proposed regulations that would authorize employer-sponsored Health Reimbursement Accounts (“HRAs”) to reimburse employee premiums for individual health insurance.  This is a 180-degree change from the current rule prohibiting reimbursement for individual health insurance premiums, and the proposed regulations, when and […]

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Texas Judge Rules Affordable Care Act Unconstitutional

United States District Court Judge Reed O’Connor of the Northern District of Texas ruled in favor of an argument by a group of states attorneys general that the Patient Protection and Affordable Care Act (“ACA”) was unconstitutional.  This decision was reached in part based on the 2017 reduction of the individual mandate penalty to zero.  […]
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Update: Are You Ready for ACA Reporting?

12/4/2018 Update:  The IRS recently released Notice 2018-94 which extends the deadline for employers to provide Forms 1095-B and 1095-C to individuals.  This deadline is now March 4, 2019, instead of January 31, 2019.  The deadlines for filing Forms 1094-B, 1094-C, 1095-B, and 1095-C with the IRS remain the same. Prepare Now for March 2019 […]
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