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Lockton Health Reform and Compliance
IRS gives employers more time to furnish 1095-Cs to employees, HHS extends national health emergency

IRS gives employers more time to furnish 1095-Cs to employees, HHS extends national health emergency

The IRS has again (as it has in past years) extended the deadline to furnish Forms 1095-C to Affordable Care Act (ACA) full-time employees. The Service has moved the deadline to furnish the forms for 2020 from Jan. 31 to March 2, 2021. The deadlines for filing those...

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Feeling good about your ACA reporting compliance? A federal audit might foreshadow a more intolerant IRS

Feeling good about your ACA reporting compliance? A federal audit might foreshadow a more intolerant IRS

The IRS has alarmed many employers over the last few years by sending 226-J letters assessing potential penalties for alleged violations of the employer mandate under the Affordable Care Act (ACA). While in most cases the employers have been able to dodge those penalties by convincing the IRS that the employer had satisfied the mandate but had merely misreported that fact to the IRS, a Treasury Department audit reports wants the IRS to become less forgiving of those errors in the future.

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IRS proposes rules allowing HRA reimbursement of direct primary care and healthcare sharing ministry fees

IRS proposes rules allowing HRA reimbursement of direct primary care and healthcare sharing ministry fees

The IRS has proposed regulations that would treat direct primary care arrangement (DPCA) fees as medical care or medical insurance, opening the door to their reimbursement from health reimbursement arrangements. While the proposal is unsurprising in many respects, the definitive guidance is welcome.

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Federal authorities provide limited coronavirus-related relief for plan sponsors and individual taxpayers

Federal authorities provide limited coronavirus-related relief for plan sponsors and individual taxpayers

Along with the immediate and unique challenges that the COVID-19 pandemic has presented to employers, these same employers – in their capacity as plan sponsors – are still tasked with their routine benefits plan reporting responsibilities. Happily, federal authorities have provided relief related to these obligations and deadlines.

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State-mandated or encouraged insurance premium payment grace periods, and the risks they pose to ERISA plan sponsors

State-mandated or encouraged insurance premium payment grace periods, and the risks they pose to ERISA plan sponsors

In response to the coronavirus pandemic, some states have prohibited or pointedly encouraged carriers from canceling benefits policies, so for some employers, deferring premium payments appears to be a win-win – employers retain cash for other immediate needs and employees don’t lose coverage. However, employers and their plans’ fiduciaries should be cautious for several reasons.

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