Author: Sharon Freilich

“CURES ACT” Authorizes Small Employers to Reimburse Employees for Health Insurance Costs

One major area of confusion and annoyance created by the Affordable Care Act (the “ACA”) has finally been put to rest with the enactment of the 21st Century Cures Act on December 13, 2016 (the “Cures Act”).  Many small employers were chagrined by the IRS pronouncement in 2013 (IRS Notice 2013-54) that the ACA prohibited…

Read more

House Passes Small Business Healthcare Relief Act

Despite repeated guidance from the IRS that employer payment plans violate insurance reforms under the Affordable Care Act (the “ACA”), many small employers continue this arrangement of reimbursing employees for their cost of health insurance purchased on the individual market. Under current law, employers who do not sponsor a group health plan but instead reimburse…

Read more

Deadline Extended For ACA Information Reporting Forms

The IRS has extended the deadlines for furnishing to employees the new Forms 1095 and filing these Forms with the IRS.  The Forms are designed to confirm compliance with the employer and individual health insurance mandates under the Affordable Care Act.  IRS Notice 2016-4 provides the following new deadlines: Furnishing to Employees: 2015 Forms 1095-B, Health Coverage…

Read more

Medical Insurance Premium Reimbursement — A Brief Reprieve for Small Employers

Some employers – particularly smaller ones – have assisted their employees to obtain health insurance by reimbursing them for the cost of insurance they purchase in the individual market.  Does this practice satisfy the requirement of the Affordable Care Act?  On February 18, 2015, the Internal Revenue Service issued Notice 2015-17 (“the Notice”), which reiterates…

Read more

New Guidance – Is that Rollover Contribution Valid?

Since 1992, the ability to move retirement money from one qualified plan to another qualified plan or individual retirement account has been simplified.  One hiccup in this easing process has been determining the level of due diligence the recipient plan must do to confirm that the proposed rollover contribution is coming from a valid source. …

Read more

Stand-Alone Health Reimbursement Arrangements May Not Be Dead After All

Many employers offer employees Health Reimbursement Arrangements (“HRAs”) to assist employees meet their health care related expenses.  Often such employer funded arrangements are not “integrated” with an insured health plan, rather they are offered as a “stand-alone” arrangement.  On September 13, 2013, the Internal Revenue Service with the concurrence of the U.S. Departments of Labor…

Read more

Connecticut Law Requires Employers to Adopt Cafeteria Plans

In 2007 Connecticut adopted a law  requiring employers to adopt cafeteria plans if their employees are required to pay a portion of the health insurance premium for employer-sponsored health insurance through payroll deduction.  Connecticut wanted to make sure that employees would have the opportunity to pay such premiums on a pre-tax basis.  This law did…

Read more