ACA Quarterly Review – First Quarter 2017

March 21, 2017: IRS To Continue Processing Tax Returns Without Health Coverage Information Pursuant to a recent executive order, the Internal Revenue Service (IRS) will continue to accept for processing tax returns in instances where a taxpayer does not indicate their health coverage status.


March 8, 2017: HHS Releases Training Materials for ACA Section 1557 Compliance

The U.S. Department of Health and Human Services (HHS) has released training materials to aid covered entities in complying with the requirements of section 1557 of the Affordable Care Act (ACA), which prohibits discrimination on the basis of race, color, national origin, sex, age, or disability in any health program or activity that receives federal financial assistance. Most private employers are exempt from the requirements of ACA Section 1557.


March 8, 2017: How Summer Help May Affect ALE Status

Employers looking to hire seasonal workers this summer are reminded that there is an exception when measuring workforce size to determine whether they are an applicable large employer (ALE) subject to the Affordable Care Act’s employer shared responsibility (“pay or play”) provisions.

March 1, 2017: New Expiration Date for Health Insurance Exchange Notices is March 31, 2017

The U.S. Department of Labor’s Employee Benefits Security Administration (EBSA) has extended the effective date of its model Health Insurance Exchange Notices through March 31, 2017. Previously, these model notices expired on February 28, 2017. No other changes have been made to these notices.

February 28, 2017: IRS Provides Extension for Qualified Small Employers to Furnish Initial Written HRA Notice

The Internal Revenue Service (IRS) has extended the period for an employer to furnish an initial written notice to its eligible employees regarding a qualified small employer health reimbursement arrangement (QSEHRA) and has delayed associated penalties until further guidance is issued.


February 27, 2017: Small Businesses May Be Able to Keep Existing Health Coverage Through Calendar Year 2018

A previously extended transitional policy which allows health insurance issuers, at their option, to continue group coverage that would otherwise be terminated or cancelled has been extended further-to policy years beginning on or before October 1, 2018, provided that all policies end by December 31, 2018.


February 21, 2017: How to Correct ACA Information Reporting Errors (Forms 1094 and 1095)

With the Affordable Care Act information reporting deadlines for the 2016 calendar year approaching, employers should confirm the accuracy of all information returns and correct any errors as soon as possible with both the IRS and their employees.


February 17, 2017: HHS Proposes Changes to Individual Insurance Market The U.S Department of Health and Human Services has issued a proposed rule that would amend the timing of the annual Health Insurance Marketplace (“Marketplace”) open enrollment period for the 2018 plan year and increase pre-enrollment eligibility verification for special enrollment periods, among other things.


February 8, 2017: Reminder: New Versions of SBC Template and Related Documents for Use On or After April 1, 2017

New versions of the Summary of Benefits and Coverage (SBC) template, instructions, uniform glossary, and related documents are required for use on or after April 1, 2017.

January 24, 2017: IRS Issues Guidance on New Individual Mandate Hardship Exemption

The Affordable Care Act’s “individual mandate” provision requires every individual to have minimum essential health coverage for each month, qualify for an exemption, or make a penalty payment when filing his or her federal income tax return. Recently, the Internal Revenue Service (IRS) released guidance allowing certain individuals eligible for the Health Coverage Tax Credit (HCTC) to qualify for a new hardship exemption.


January 19, 2017: 3 ACA Facts for Small Employers

The Internal Revenue Service is reminding small employers about three key provisions of the Affordable Care Act (ACA) that may or may not affect them. January 17, 2017: New Guidance on Applicability of ACA’s Market Reforms to Family HRAs

The U.S. Departments of Labor, Health and Human Services, and Treasury have published new FAQs clarifying how family HRAs (HRAs available to reimburse the medical expenses of an employee’s spouse and/or dependents) can be integrated with other group health plan coverage to satisfy the market reforms of the Affordable Care Act (ACA).


January 12, 2017: New FAQs on ACA Information Reporting and Preventive Services Requirements Released

Two sets of FAQs related to the Affordable Care Act have been updated