Affordable Care Act (ACA) Advisory
The ACA and Affordability – What is this anyway?
While non-ALEs who offer group health coverage may have small group carrier requirements about affordability for their employees, these non-ALE employers are not subject to the Section 4980H affordability requirements and cannot be held liable for any employer shared responsibility penalties. Now that the IRS is actively enforcing the employer shared […]
Those 226J Letters –Insights into IRS Enforcement Of Employer Shared Responsibility Penalties
Everyone’s heard the old saying about the “third time’s a charm.” Well, by now most brokers are aware the IRS is now LOOKING BACK and enforcing the employer mandate by issuing penalty notification letters to applicable large employers (ALEs) suspected of noncompliance with the employer shared responsibility requirements during the […]
Can the Benefit Booklet Provided by Our Plan’s Insurer Serve as the SPD?
QUESTION: We have a fully insured group health plan. The insurer provides a state-law required certificate of insurance booklet that describes the coverage provided under the plan. Can we use that booklet as the summary plan description (SPD) for this plan? ANSWER: The booklet probably cannot serve as the SPD on its […]
IRS Publishes Indexed ACA Affordability Percentages for 2019
In Rev. Proc. 2018-34, the IRS issued the indexed affordability percentages relevant to applicable large employers (ALEs) who must offer minimum essential coverage meeting certain requirements to fulltime employees and their dependents or risk exposure to employer shared responsibility penalties. In 2019, such coverage will be deemed “affordable” if the […]
IRS Restores 2018 HSA Limits and Announces 2019 HSA Limits
In Rev. Proc. 2018-17, the IRS restored the previously issued $6,900 contribution limit for individuals with family HDHP coverage in 2018. The IRS had recently lowered the limit to $6,850 as a consequence of the Tax Cuts and Jobs Act, but due to stakeholder concerns, the IRS will now allow […]