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More health care reform FAQs issued
  • Hodgson Russ LLP
  • USA
  • January 4 2011

Over the past several months DOL, HHS, and the IRS (collectively, the Agencies) have issued a series of frequently asked questions (FAQs) regarding the implementation of the Affordable Care Act


Enforcement of insured plan nondiscrimination rules delayed
  • Hodgson Russ LLP
  • USA
  • January 4 2011

As many employers are by now well aware, the Affordable Care Act imposes nondiscrimination rules on insured non-grandfathered group health 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


IRS issues notice regarding nondiscrimination rule for insured plans
  • Hodgson Russ LLP
  • USA
  • November 29 2010

The IRS issued Notice 2010-63 inviting public comments on the application of rules prohibiting insured group health plans from discriminating in favor of highly compensated individuals (HCIs


New grandfathered plan regulations permit insurance contract changes
  • Hodgson Russ LLP
  • USA
  • February 11 2011

Under the Affordable Care Act, group health plans are required to comply with a number of new insurance market reform requirements


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


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


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