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EEOC issues regulations addressing ADA requirements for employer wellness programs

The Equal Employment Opportunity Commission (EEOC) has issued long awaited proposed regulations on how employers can structure their wellness programs in relation to the American with Disabilities Act (ADA).

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Notice of Coverage through the Benefit Exchange

Starting in 2015, the employer mandate is being phased in and employers with 100 or more full-time equivalents (FTEs) may pay an additional tax on any eligible individuals who are not offered coverage or for whom coverage is unaffordable. In 2016, employers with 50 or more FTEs will be required to comply as well.

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The Longshore and Harbor Workers’ Compensation Act Coverage

One of the great benefits of living near oceans, rivers or lakes is the beautiful waterfront vistas we get to enjoy. However, for those involved in the world of construction, those waters can also be dangerous to navigate in terms of Workers’ Compensation insurance.

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IRS Releases Final Reporting Forms and Instructions

The IRS has released final forms and instructions for the ACA employer reporting requirement. Applicable large employers (ALEs, generally those with 50 or more FTEs), and small employers with self-funded group health plans, are required to report certain plan information to the IRS and to provide statements to employees, beginning in 2016 for calendar year 2015 health plan and coverage data.

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SBC and Uniform Glossary Modifications

On Dec. 22, 2014, the Department of Labor (DOL), Health and Human Services (HHS) and the Treasury (IRS) jointly released proposed rules regarding the requirements relating to the Summary of Benefits and Coverage (SBC) and the accompanying uniform glossary. Most notably, these proposed rules shorten the template to 2½ pages; add a new example to illustrate coverage; add new definitions to the uniform glossary; and provide updated templates, instructions, and other related documents.

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CMS Extends the Deadline to Report Membership Data for the Transitional Reinsurance Contribution

On Friday November 14th the Department of Health and Human Services’ Centers for Medicare & Medicaid Services (CMS) announced an extension of the deadline for submission of plan membership data for the transitional reinsurance program (TRP). Employer/plan sponsors of self-funded plans were originally required to report membership by November 17th, 2014, but the filing deadline has now been extended to December 5th, 2014.

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Supreme Court to Hear ACA Case

On Friday Nov. 7th the Supreme Court announced they plan to consider challenges to the government’s policy of providing subsidies to individuals who purchase health insurance through Healthcare.gov, the federally run Marketplace. The case will be heard early in 2015, with a decision likely at the end of the Court’s term early in the summer of 2015.
Background

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Employer Can Not Pay for Employee’s Individual Health Insurance

In the most direct guidance released to date, the DOL has issued new FAQs that make it clear employers are not permitted to pay for the cost of individual health insurance for employees, even if the payments are made on an after-tax basis.

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Health Plan ID (HPID) Requirement Delayed

On October 31st  the Centers for Medicare and Medicaid Services (CMS) announced an indefinite delay in the Health Plans ID (HPID) requirements applicable to self-funded employer sponsored health plans. Officially described as an enforcement delay, the announcement means that large self-funded employers will not be required to obtain an HPID by November 5th, 2014 as originally required. No further information regarding a new deadline, or other changes to the HPID requirements, was contained in the announcement. 

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