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IRS Releases Draft ACA Reporting Form Instructions

On August 28, the Internal Revenue Service (IRS) released draft instructions for completing health insurance reporting forms required under the Affordable Care Act (ACA). The release of the instructions comes a month after the IRS released the draft forms employers and insurers must use to report information regarding health care coverage. Section 6056 of the Internal Revenue Code, as added by the ACA, requires “applicable large employers” to provide information to the IRS about the type of health coverage offered to their full-time employees for purposes of the large...

EEOC Directly Challenges Wellness Program for the First Time

The EEOC has filed its first lawsuit directly challenging the operation of a wellness program. In EEOC v. Orion Energy Systems, Civil Action 1:14-cv-01019, the EEOC alleged that the employer imposed a wellness program on its employees in violation of the ADA. According to the complaint filed on August 20, 2014 in the U.S. District Court for the Eastern District of Wisconsin, the EEOC claims that the defendant, Orion Energy Systems, administered a wellness program in which employees were asked to complete a health risk assessment, which included questions regarding medical history and blood...

Agencies Issue New Regulations Governing ACAs Contraception Mandate

On August 27, 2014, new interim final regulations were published by several administrative agencies entitled "Coverage of Certain Preventive Services Under the Affordable Care Act." On the same day, the agencies released a Notice of Proposed Rulemaking with the same title.  As we have previously written, the Patient Protection and Affordable Care Act (ACA) imposes insurance coverage obligations on both non-profit and for-profit religious organizations.  These coverage mandates have been the subject of extensive litigation.Both the final interim and proposed regulations...

California Repeals 60-Day Limit on Health Insurance Waiting Periods

Under the Patient Protection and Affordable Care Act (ACA), a “waiting period” is defined as the period that must pass before coverage for an individual who is otherwise eligible to enroll under the terms of a group health plan can become effective. The ACA prohibits group health plans and group health insurance issuers from imposing a waiting period that exceeds 90 days after an employee is otherwise eligible for health coverage. Generally, an individual is “eligible” to enroll in a health plan if he or she has met the plan’s substantive eligibility conditions,...

Need Help Finding Your Plan's Missing Participants?

The Department of Labor (DOL) recently issued a new Field Assistance Bulletin (FAB 2014-01) that provides guidance regarding the steps a plan administrator should take to fulfill his or her fiduciary duty to locate and distribute account balances to missing participants in terminated defined contribution plans.  FAB 2014-01 replaces the 10-year-old Field Assistance Bulletin 2004-02 (FAB 2004-02).  Since FAB 2004-02, many changes have occurred that warranted updated guidance.  These changes include the discontinuance of the letter-forwarding services by the Internal Revenue...


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Format: 2014-09-22
Format: 2014-09-22