Seyfarth Synopsis: In light of the end of the COVID-19 National Emergency and Public Health Emergency (see our prior blog post here), the Internal Revenue Service (“IRS”) has announced the end of prior COVID-19-related special rules for health plan coverage.
On June 23, 2023, the IRS issued Notice 2023-37 to clarify the compatibility of
Seyfarth Synopsis: The Consolidated Appropriations Act, 2021 (“CAA”) contains a requirement that that group health plans may not have agreements with service providers that would restrict certain information that the plan may make available to another party (the “Gag Clause Prohibition”) and must attest on an annual basis that they are complying (the “Compliance Attestation”).
April 11, 2023 Update: On April 10, 2023, President Biden signed legislation which ended the national emergency (NE) immediately. The public health emergency (PHE) is still expected to end on May 11, 2023. The Outbreak Period discussed below will still end on July 10, 2023 (i.e. 60 days after the date previously announced by the
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. |