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Health Coverage Information Reporting Deadline Looms
Dec 21, 2015
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Overview   Under the Affordable Care Act (“ACA”), in order to obtain the information necessary for the IRS to administer the employer shared responsibility mandate (often referred to as the “play or pay” rule) and premium tax credit, “applicab...
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Proposed EEOC Rules Define “Voluntary” for Purposes of Wellness Programs
May 01, 2015
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The federal Equal Employment Opportunity Commission (the “EEOC”) recently released long-awaited guidance on when employees’ participation in workplace wellness programs will be considered “voluntary” for purposes of the Americans With Disabilities Ac...
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Self-Insured Health Plans and PCORI Fees
Apr 19, 2013
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Plan sponsors of self-insured health plans are required to pay a fee to fund the Patient-Centered Outcomes Research Institute. These fees are referred to as “PCORI fees.” Issuers of health insurance policies are also required to pay PCORI fees with r...
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Health Care Reform: Will You Play . . . or Pay?
Apr 08, 2013
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One of the most significant elements of health care reform is its requirement that, beginning January 1, 2014, certain employers must make health coverage available to their full‑time employees (and their dependents) or else face a penalty. These “pl...
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New Summary of Benefits and Coverage Requirement for Group Health Plans
Sep 19, 2012
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What is a summary of benefits and coverage (“SBC”)? Under the Patient Protection and Affordable Care Act (“PPACA”), an SBC that describes the benefits and coverages of each “benefit package” under a group health plan must be provided to participants...
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New Fee Disclosure Requirements for Plans with Participant-Directed Investments
Apr 26, 2012
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The Department of Labor (the “DOL”) has issued final regulations that will require fiduciaries of individual account plans with participant-directed investments to periodically disclose to participants certain plan and investment-related information....
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