America’s cultural wars may be opening up a new front, and group health plans may be caught in the fray. Since the US Supreme Court decision in Dobbs ended almost fifty years of constitutional protection for abortion rights and gave states the authority to regulate abortion, lawmakers (or citizens) have either enacted new prohibitions on

As discussed in a previous blog, the Patient-Centered Outcomes Research Institute (PCORI) is an independent nonprofit research organization that funds comparative clinical research, among other things. PCORI is funded through annual fees — provided for in the Affordable Care Act — paid by insurers of fully insured health plans and sponsors of self-insured health

Under the Affordable Care Act (ACA), applicable large employers (ALEs) — i.e., those with, on average, fifty (50) or more full-time or full-time-equivalent employees in the preceding year — must offer in the following year affordable, minimum value group health plan coverage to their full-time employees and those employees’ dependents or risk imposition of

The Patient-Centered Outcomes Research Institute (“PCORI”) is an independent nonprofit research organization that funds comparative clinical research, among other things.  PCORI is funded through annual fees — provided for in the Affordable Care Act — paid by insurers of fully-insured health plans and sponsors of self-insured health plans, including health reimbursement arrangements (“HRAs”) that are

On April 19, 2022, the Departments of Labor, Health and Human Services, and the Treasury issued additional guidance under the Transparency in Coverage Final Rules issued in 2020.  The guidance, FAQs About Affordable Care Act Implementation Part 53, provides a safe harbor for disclosing in-network healthcare costs that cannot be expressed as a dollar

In furtherance of the Biden Administration’s January 28, 2021, Executive Order 14009 and April 5, 2022, Executive Order 14070 to protect and strengthen the ACA, the Treasury Department and IRS published a proposed rule on April 7, 2022, advancing an alternative interpretation of Internal Revenue Code Section 36B.  Employers can breathe a sigh of relief

The IRS just released IRS Notice 2022-04 that provides the updated fee for Patient-Centered Outcomes Research Institute (PCORI) paid by fully insured and self-funded health plans for the upcoming tax reporting period.

As we stated before, even though the original PCORI fee assessments under the Affordable Care Act were scheduled to end after September

The CAA Transparency Rules Will Let Plans and Participants Know.  The Department of Labor, Health and Human Services, and the IRS (collectively the Departments) recently released the Interim Final Rules with a request for Comment (IFC), Prescription Drug and Health Care Spending.  These rules implement Section 204, Title II, another phase of the transparency provisions

Just three weeks ago, we wrote that employers likely would not receive certain Affordable Care Act reporting relief to which they’ve become accustomed.

But in a welcome turn of events, the IRS just released proposed regulations that make permanent a 30-day automatic extension for furnishing Forms 1095-B and 1095-C to individuals.  Such forms will now

As employers with 50 or more full-time (or full-time equivalent) employees are well aware, the Patient Protection and Affordable Care Act (”ACA”) requires annual submission of Forms 1094-C and 1095-C with the Internal Revenue Service, and distribution of Forms 1095-C.  These submissions and distributions are generally due:

 Furnishing of Forms 1095-C to employees: January 31