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Play Time is Over: IRS Reveals Process for Assessing ACA Penalties

USA - November 27 2017 The Affordable Care Act (ACA) introduced a “pay or play” scheme, effective January 1, 2015, in which Applicable Large Employers (ALEs) must offer…

Meredith Jacobowitz, Serena F. Yee

Stop-Loss Policies, How Low Can You Go?

USA - April 20 2017 On April 5, the “Self-Insurance Protection Act” passed the House and moved to the Senate. This bill, if enacted, would amend ERISA, the Public Health…

Christopher J. Rylands

Fiduciary Rule Under Review - Delayed Applicability Date

USA - March 1 2017 In a prior post, we covered President Trump’s order directing the Department of Labor to review the new regulation and, as it deems appropriate, to…

Christopher J. Rylands

Just Push Pause: Revisiting Proposed Regulations

USA - February 21 2017 On January 20, 2017, President Trump signed an Executive Order entitled “Regulatory Freeze Pending Review” (the “Freeze Memo“). The Freeze Memo was…

Brian W. Berglund

New ACA FAQs - Special Enrollment, Women’s Preventive Care and a Cure for the HRA that Ails You (If You’re Small Enough)

USA - December 28 2016 In the latest round of FAQs on ACA implementation (now up to 35 if you’re keeping track), the DOL, HHS and Treasury Department addressed questions…

Christopher J. Rylands