The Department of Labor (DOL) has just published a series of FAQs regarding premium reimbursement arrangements. Specifically, the FAQs address the following arrangements:
An arrangement in which an employer offers an employee cash to reimburse the purchase of an individual market policy.
Where an employer provides cash reimbursement for the purchase of an
Just as employers are gearing up to prepare for compliance with the Shared Responsibility rules under the ACA, a pair of decisions from two federal appeals courts has thrown a curve ball into what was already a complicated assessment of risk for employers and raised new questions.
The U.S. Court of Appeals for the District
The Patient Protection and Affordable Care Act requires employers to furnish employees a notice of the availability of coverage through public health insurance exchanges, i.e., the “Marketplace”. The Department of Labor requires that employers give employees the notice by October 1, 2013. As highlighted in our earlier blog post, Department of Labor Technical Release 2013-02
A provision of the 2010 health care reform law requires employers to provide notices, by March 1, 2013, to all employees regarding the availability of health coverage options through the state-based exchanges created pursuant to that law. In January, the Department of Labor had announced delayed enforcement of the exchange coverage notice provision (which added Section