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Seyfarth Synopsis: The Biden Administration has announced that the COVID-19 Public Health Emergency (PHE) and COVID-19 National Emergency (NE) will expire May 11, 2023.

In response to the COVID-19 pandemic, two separate emergency declarations have been in effect: (1) the PHE; and (2) the NE. For more information regarding the Emergency Declarations, COVID Relief

Seyfarth Synopsis: Recently the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued regulations (the “Final Regulations”) which finalized previously proposed relief for furnishing Forms 1095-B and 1095-C to individuals. Notably, the Final Regulations provide a permanent 30-day extension to the due date for furnishing Form 1095-C to individuals. This extension was previously granted in the 2021 final instructions for completing Forms 1094-C and 1095-C for 2021 (see our blog here) issued in December 2021.

Continue Reading Permanent Extension to the ACA Reporting Deadline

Seyfarth Synopsis: The IRS has announced an increase to the applicable dollar amount for determining the Patient-Centered Outcomes Research Institute (“PCORI”) Fee for 2023 as well as other health and welfare limits.

The Affordable Care Act (ACA) established the PCORI to support research on clinical effectiveness. The PCORI is funded in part by fees paid

Seyfarth Synopsis: The IRS has announced adjustments decreasing the affordability threshold for plan years beginning in 2023, which may cause employers to have to pay more for ACA compliant coverage in 2023.

The IRS recently released adjustments decreasing the affordability threshold for plan years beginning in 2023 in Revenue Procedure 2022-34.

Under the Affordable

Seyfarth Synopsis: The IRS has announced adjustments decreasing the affordability threshold and increasing employer shared responsibility payments for plan years beginning in 2022.

On May 9, 2022, the IRS updated the Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act page on the IRS website to include 2022 indexing adjustments for

Seyfarth Synopsis: The IRS has announced the adjustment to the applicable dollar amount for the Patient-Centered Outcomes Research Institute (“PCORI”) Fee for 2022.

The Affordable Care Act (ACA) established the PCORI to support research on clinical effectiveness. The PCORI has been funded in part by fees paid by certain health insurers and sponsors of self-insured

Seyfarth Synopsis: The IRS has released final instructions for completing Forms 1094-C and 1095-C for 2021. Notably the instructions provide that the due date for furnishing Form 1095-C to individuals is extended to March 2, 2022. As expected, the instructions no longer offer penalty relief for good faith incorrect or incomplete filings and Form

The Internal Revenue Service (IRS) recently released 2022 cost-of-living adjustments applicable to dollar limitations for employer-sponsored health and welfare plans and retirement plans.

The changes in the 2022 cost-of-living adjustments for employer-sponsored health and welfare plans are summarized in the table below:

Health and Welfare Plan Limits (Rev. Proc. 2021-45 and Rev. Proc.

The Consolidated Appropriations Act of 2021 (“CAA”) offers significant relief for employers sponsoring flexible spending accounts. After much clamoring from the employer community, the IRS finally issued clarifying guidance in the form of Notice 2021-15 (the “Notice”). Check out our full Legal Update for details.

Synopsis: On January 20, 2021, the Biden Administration revoked the Trump Administration Executive Order (EO) which had restricted agency Guidance. On January 27, 2021, the Department of Labor (DOL) rescinded the “PRO Good Guidance” rule that it had issued pursuant to the Trump EO – a rule that limited the force of informal guidance in