06 May 2015

New HSA/HDHP Limits for 2016

The IRS has announced the inflation-adjusted limits for health savings accounts and high deductible health plans for 2016.  The limits will be increasing.  Below is a summary: If you have any questions regarding HSAs or high deductible health plans or the new limits, please contact the author or any member of the Employee Benefits practice […]


20 April 2015

New EEOC Regs Guide ADA Compliance for Employer Wellness Programs

The EEOC has proposed new regulations to help employers design their wellness programs in a manner which complies with the Americans with Disabilities Act (ADA). While the guidance is welcome, it unfortunately does not mirror the HIPAA/ACA wellness program rules. As a result, wellness programs associated with health plans will be required to follow two […]


16 April 2015

IRS Improves Correction Program for 401(k) and 403(b) Plans

Overview The IRS announced new lower-cost correction procedures for a plan sponsor that failed to properly implement an employee’s 401(k) or 403(b) contributions, or failed to inform an employee of the opportunity to make these contributions. The new rules also provide relief if automatic contributions were not correctly administered. Background Information The IRS maintains a […]


17 March 2015

Health Care Reform Update: Happy Five Year Anniversary

It’s hard to believe that employers have been living with the Patient Protection and Affordable Care Act (also known as Health Care Reform) for almost 5 years. The law was enacted on March 23, 2010 and continues to have a significant impact on employers. The number of requirements and the volume of regulations and other […]


17 March 2015

IRS Publishes Helpful Guidance on Reimbursing Employees’ Individual Health Insurance Premiums

The IRS has published new guidance to clarify that no matter how a reimbursement arrangement is structured or what the reimbursement arrangement is named, reimbursement of employees’ individual health insurance policies violates certain mandates under Health Care Reform. The new IRS Notice 2015-17 affirms and expands upon earlier guidance addressing this issue. To encompass all […]


17 March 2015

IRS Releases Final Forms and Instructions to Comply With ACA Employer Reporting Requirements

In February 2015, the IRS released “final” versions of both the forms and instructions for purposes of “individual mandate reporting” under Section 6055 of the Internal Revenue Code (Code) and “pay or play reporting” under Section 6056 of the Code. These forms and instructions replace drafts released by the IRS in 2014.  While there were […]


17 March 2015

IRS Releases Initial Guidance on The Cadillac Tax

The IRS recently released Notice 2015-16, its first guidance on the excise tax on high cost employer-sponsored health coverage (i.e., the Cadillac tax) which will become effective in 2018. The Cadillac tax is a 40 percent nondeductible excise tax on the aggregate cost of “applicable employer-sponsored coverage” (referred to in the Notice and here as […]


17 March 2015

Priority Alert – Health Care Reform, March 17, 2015

The Patient Protection and Affordable Care Act was enacted on March 23, 2010 and continues to have a significant impact on employers. In the past five years, the number of requirements and the volume of regulations and other guidance which has been issued to date is unprecedented in the employee benefit arena. This issue covers the latest from the IRS including the final forms and instructions on employer reporting requirements, the initial guidance on the Cadillac tax, guidance on reimbursing employees’ individual health insurance premiums, and the temporary reinsurance program fee for 2016.