Highlighted Posts

Posts from May 2014.
Lyndsey Barnett

I asked myself this question many times and it took me quite some time to find the answer. The regulations on the new 6055 and 6056 rules make it very clear that even non-calendar year plans must begin reporting for the period beginning on January 1, 2015. The 6056 report requires a large employer to report each of its full-time ...

Jamie Scott

Where is one place you should never find private medical records? Dylan was right - the answer is blowing in the wind. But that is exactly what a man found while driving down a Kansas City street. When the man traced the flying records back to their source, he found a crew dumping the records into an open dumpster at Research Hospital ...
Lyndsey Barnett

The general rule is that safe harbor 401(k) plans may not be amended mid-year with very limited exceptions.  This rule is one that often frustrates plan sponsors and is one that the IRS has recently said it is taking under consideration.  While the general rule still holds true, the IRS recently published guidance stating that plans ...

Lyndsey Barnett

The ACA has several new reporting requirements for insurers, self-funded plans and large employers. These new reports, referred to as the Section 6055 and 6056 reports, are intended to help the IRS determine who is subject to the individual mandate penalty and the employer pay or play penalties. Due to the complexity of the ...

Jamie Scott

The Urban Institute is generally viewed as a center-left policy research institute that has been supportive of the Affordable Care Act. That is why it is so surprising that it just published a brief suggesting the elimination of the employer mandate, along with its substantial penalties for failing to offer employees affordable ...
Jamie Scott

New York and Presbyterian Hospital (“Presbyterian”) and Columbia University (“Columbia”) are affiliated as the New York Presbyterian Hospital/Columbia University Medical Center.  According to a recent report published by the HHS Office of Civil Rights (“OCR”), Presbyterian and Columbia are separate covered ...

Lyndsey Barnett

The short answer is yes. While I get this question a lot from clients, Health Care Reform did not change the COBRA requirements. The DOL must want to ensure we understand COBRA is still relevant because earlier this month it released a new model COBRA election notice. The new model notice includes significant changes from the ...

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