Draft 2015 Form 1095-C and Instructions

As background, beginning with calendar year 2015, an applicable large employer (“ALE”) must use Forms 1094-C and 1095-C to report the information required under Internal Revenue Code sections 6055 and 6056 about offers of health coverage. The information reported...

New Law Clarifies Employer Mandate and HSA Eligibility for Veterans

On July 31, 2015, President Obama signed into law H.S. 3236, Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. Notably, the law makes changes affecting the employer mandate and HSA eligibility as to individuals who are (or were formerly)...

Additional Guidance Issued on the Cadillac Plan Tax

Beginning January 1, 2018, a 40% excise tax will apply on the cost of applicable coverage that exceeds prescribed thresholds. Commonly, this is referred to as the “Cadillac Plan Tax.” The 2018 thresholds are $10,200 for self-only coverage and $27,500 for coverage...

Reduction in Hours Subject to Lawsuit in New York

The first complaint was filed challenging the permissibility of reducing hours below 30 per week in order to avoid the Employer Penalty. The complaint was filed in a New York district federal court on behalf of 10,000 workers at Dave and Buster’s. The plaintiffs...

Interim Guidance Addresses Expatriate Health Coverage

The Department of the Treasury, Department of Labor, and Department of Health and Human Services (collectively, the “Departments”) recognize that insurers and plan sponsors may need additional time to modify their current expatriate health plans to comply with the...