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New COBRA subsidy rules
  • Hodgson Russ LLP
  • USA
  • March 19 2010

The Temporary Extension Act of 2010 (TEA), signed into law by President Obama on March 2, 2010, includes a number of important changes to the COBRA premium subsidy provisions enacted as part of the American Recovery and Reinvestment Act of 2009 (ARRA


MEWA held to be not fully insured under ERISA
  • Hodgson Russ LLP
  • USA
  • April 15 2011

When unrelated employers join together in an association or other group to purchase or arrange for health insurance, the association is defined as a "multiple employer welfare arrangement" or "MEWA" under the law


Grace period provided for compliance with health plan claims procedures
  • Hodgson Russ LLP
  • USA
  • October 29 2010

Treasury, the Department of Labor, and the Department of Health and Human Services jointly issued a technical release giving group health plans until July 1, 2011, to comply with the new internal claims and appeals procedures required under the Patient Protection and Affordable Care Act (PPACA


Mandatory W-2 reporting of the cost of medical coverage delayed
  • Hodgson Russ LLP
  • USA
  • October 29 2010

Under the PPACA, employers are required to report the cost of employer-sponsored health coverage on their employees' 2011 Forms W-2 (generally issued in early 2012


Agencies issue amendments to the PPACA claims and appeals processes
  • Hodgson Russ LLP
  • USA
  • July 29 2011

The Treasury, DOL, and the Department of Health and Human Services jointly issued amendments to the interim final rules governing the internal claims and appeals and the external review processes required under the Patient Protection and Affordable Care Act (PPACA


Treasury, IRS seek public input and comment on health care reform shared responsibility provisions
  • Hodgson Russ LLP
  • USA
  • July 29 2011

Under health care reform, employers with 50 or more full-time employees that do not offer affordable health coverage to their full-time employees may be required to make a shared responsibility payment


Plan administrator not obligated to provide benefit accruals for unpaid hours
  • Hodgson Russ LLP
  • USA
  • July 29 2011

Nurse participants in a hospital retirement plan were upset that their unpaid meal breaks, during which they were required to work, and an unpaid 20-40 minute period of patient status review before the official start of their shifts were not counted for benefit purposes in the hospital's retirement plans


Health reimbursement arrangements and waivers: immediate action required
  • Hodgson Russ LLP
  • USA
  • November 19 2010

Under the Patient Protection and Affordable Health Care Act (PPACA), a group health plan's ability to impose annual limits on essential health benefits is restricted for plan years beginning before January 1, 2014 and prohibited altogether for plan years beginning on or after January 1, 2014


Small business tax credit for employer health insurance contributions
  • Hodgson Russ LLP
  • USA
  • May 28 2010

The Internal Revenue Service (IRS) recently issued guidance on a tax credit made available through the Patient Protection and Affordable Care Act that benefits certain small employers who help defray the cost of their employees' health insurance premiums


New guidance regarding the age-26 dependent coverage mandate
  • Hodgson Russ LLP
  • USA
  • May 28 2010

Under the Patient Protection and Affordable Care Act as amended by the Health Care and Education Reconciliation Act of 2010, group health plans that extend coverage to dependent children must continue to make such coverage available until age 26