Employer Guidance

This past December, District Judge Reed O’Conner released his ruling in the case Texas v. United States. The case questioned the constitutionality of the ACA’s individual mandate after the Tax Cuts and Jobs Act of 2017 reduced the individual mandate penalty to $0. The judge ruled that the mandate without tax penalty was unconstitutional, and as a result, so was the entire ACA. It is expected that the ruling will be appealed and likely tied up for months bef... Read more
Once again (in Notice 2018-94) the IRS has extended the deadline for furnishing Forms 1095-B and 1095-C to individuals from January 31 to March 4, 2019.  The notice does not extend the due date for filing Forms 1094-B and 1094-C (and accompanying Form 1095s) with the IRS. Accordingly, the deadline remains February 28, 2019, for paper filings, and April 1, 2019, for electronic filings.  The electronic filing of  information returns (Forms 1094/1095) f... Read more
Forms 1094/1095-B (B Forms) and Forms 1094/1095-C (C Forms), and related instructions, for the 2018 tax year have been released and are provided below. Employers Subject to Reporting Applicable large employers (ALEs), who are in general, entities that employed 50 or more full-time and full-time-equivalent employees in 2017, are required to report information about the health coverage they offered or did not offer to employees for 2018. To meet this reporting... Read more
Employers who provide prescription drug coverage to those who are or may become eligible for Medicare Part D, must notify both plan members and CMS on whether the coverage provided is deemed “creditable” or “non-creditable” per the MMA Act of 2003. Creditable coverage means the prescription drug plan is at least as good as the Medicare drug benefit. Read more
In a recent Notice the IRS announced the adjusted percentage that will be used to determine whether employees' share of their 2019 premiums are considered affordable for purposes of the employer mandate. Applicable Large Employers, for the 2019 plan year, will need to apply the decreased threshold of 9.86%  to any of three "safe harbors:" •             W-2 wages •     &... Read more
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