September 30, 2019

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New Health Reimbursement Arrangements Allowed Under Final Rules

Updated: September 30th, 2019 The President signed an Executive Order on October 12, 2017, directing the U.S. Departments of Labor, Treasury, and Health and Human Services (collectively, the “Agencies”) to consider rules expanding the availability and permitted uses for Health Reimbursement Arrangements (HRAs). The clear intent was to ultimately enable employers to offer HRAs to […]

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December 29, 2019

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Affordable Care Act Reporting Relief Extended for 2019

The Internal Revenue Service just released Notice 2019-63, which extends the deadline for Affordable Care Act (ACA) Form 1095 reporting to individuals and the good faith compliance defense for reporting errors consistent with the relief that has been available in prior years.  Relief Notes Delivery of Forms 1095 to Individuals – The deadline to provide the 2019 […]

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December 27, 2019

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Repeal, Repeat, Remand – Ho Ho Hum?

The year ended with a lot of activity in the health and welfare benefits space, although much of that activity results in things continuing as they were for 2019. 2020 Federal Spending Bill Congress passed the fiscal year 2020 spending bill (the “Spending Bill”) last week, and it was signed by the President on December […]

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November 20, 2019

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IRS Releases Draft 2019 Instructions for Forms 1094/1095

After a lengthy and unexplained delay, the Internal Revenue Service released drafts of the 2019 Forms 1094-C, 1095-C and their corresponding instructions on November 13, 2019.  The forms and reporting obligations are basically unchanged from 2018.  There had been speculation that reporting might be streamlined due to the repeal of the individual mandate, but that is not the case. Minor […]

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November 18, 2019

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Construction Executive Magazine Shares Insight from Leaders in Surety Bonding

Construction Executive Magazine asked several leaders in surety bonding about the risks involved when bidding on projects outside their niche during an economic downturn. Read their responses here. Here is what Andy Thome, President of J.W. Terrill, a Marsh & McLennan Agency in St. Louis, had to say:  When branching out to geographies or niches outside […]

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November 8, 2019

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IRS Releases 2020 Limits for FSAs and Other Benefits

The Internal Revenue Service released Revenue Procedure 2019-44 earlier this week, which contains the 2020 cost-of-living adjustments for various employee benefit plans including employer sponsored health care flexible spending accounts, qualified transportation fringe benefits, and adoption assistance programs. The following provides a summary of the annual limits for these specific benefit programs along with a summary of […]

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October 28, 2019

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All That Glitters in not Gold

A Cautionary Tale about Certain Claimed Tax Savings Arrangements Disguised as Wellness Programs Promoters have long pitched some variation of the following wellness program to employers: Employees pay pre-tax contributions to participate in a self-insured group health plan; During the course of the plan year, the plan returns most or all of the employee contributions […]

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October 28, 2019

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California Mandates a Notice Requirement for Flexible Spending Accounts

But California gets an incomplete California recently enacted AB 1554, which requires employers sponsoring flexible spending accounts to notify employees of “any deadline to withdraw funds before the end of the plan year.”  The law does not define the term “flexible spending account,” but it does indicate this term is intended to include dependent care flexible spending […]

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October 28, 2019

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Medical Loss Ratio Rebates

Show Me the Money The Affordable Care Act’s (ACA) Medical Loss Ratio (MLR) standards require health insurance carriers to spend a specific percent of premium on health care services and activities that could improve quality of care. [1] If the carrier does not meet the MLR standards, it must provide rebates to the policyholders – the employer […]

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October 28, 2019

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The Affordable Care Act’s Employer Mandate: Part 3

Offers of Coverage and Avoiding Penalties This article is Part 3 in a series intended to provide an overview of the Employer Shared Responsibility provisions (also known as the “employer mandate”) under the Affordable Care Act (ACA). The employer mandate generally requires applicable large employers (ALEs) offer affordable, minimum value medical coverage to its full-time […]

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September 19, 2019

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2020 Employer Affordability Safe Harbor

Employer Mandate: Part 3 Sneak Peak We will do a deep dive into what kind of medical coverage must be offered to avoid potential employer mandate penalties in Part 3 of our Affordable Care Act (ACA) Employer Mandate series. On July 23, 2019, the IRS released Revenue Procedure 2019-29, updating the ALEM’s required contribution percentage […]

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September 18, 2019

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The Affordable Care Act’s Employer Mandate: Part 2

Determining Full-Time Employees This article is Part 2 in a series intended to provide an overview of the Employer Shared Responsibility provisions (also known as the “employer mandate”) under the Affordable Care Act (ACA). The employer mandate generally requires employers known as applicable large employers (ALEs) to offer medical coverage to full-time employees and certain […]

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