by Mark Holloway | July 6, 2015 | Health Reform
Buried in the budget law signed by the President last December is the Expatriate Health Coverage Clarification Act of 2014. Known as EHCCA, this act exempts some expat coverage from several thorny Affordable Care Act-related requirements, and treats the coverage as...
by Mark Holloway | June 25, 2015 | Employer Mandate, Health Reform
The Supreme Court today concluded that the ACA’s reference to exchanges established by “the State” is ambiguous. Does it mean one of the 50 states? Does it include the federal government’s exchange? The Court applied long-standing rules for resolving or interpreting...
by Mark Holloway | February 6, 2015 | Health Reform
When a full-time employee qualifies for premium assistance to purchase coverage on an exchange his or her employer may incur a penalty under the play or pay mandate (see our Alert). Employers will know when their employees qualify for premium assistance because...
by Mark Holloway | December 24, 2014 | Compliance Services, ERISA
Posted on behalf of Mark Holloway, J.D. – Senior Vice President and Director – Lockton Compliance Services One of the areas in the employee benefit world where agency guidance has been sorely needed is the application of federal tax and ERISA rules, particularly rules...
by Mark Holloway | November 14, 2014 | Health Reform, HIPAA
Some of you have expressed dismay at recent EEOC litigation challenging routine (and ACA/HIPAA-compliant) wellness programs for alleged violations of the Americans with Disabilities Act (ADA). Turns out Congress is a bit dismayed too. At a hearing yesterday of the...
