Healthcare Reform Update - November 16, 2017

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Employer Shared Responsibility Penalty Determination, Appeal, and Payment Process Outlined in New Sample IRS Letter

The IRS recently released a sample version of the letter that will be used to inform employers that they owe a penalty for failing to comply with the Employer Mandate. The sample Letter 226J comes amidst repeated efforts to repeal PPACA. However, because PPACA remains the law of the land, the IRS is compelled to enforce it, including the Employer Mandate. Below, we discuss what employers can expect from a Letter 226J.



Range of Issues Addressed in Proposed 2019 Notice of Benefit and Payment Parameters; Includes Peek at 4980H Penalties and Annual Cost Sharing Maximum

HHS released proposed rules in its annual Notice of Benefit and Payment Parameters guidance on October 27. The proposed rules address an assortment of issues under PPACA including risk adjustments, reinsurance, and risk corridors programs, Small Business Health Options Program (“SHOP”) guidance, Medical Loss Ratio (“MLR”) rule tweaks, and rules on essential health benefit benchmark plans, among other topics. In general, most of these rules are applicable to insurers only; however, there are rules that apply to employer. In this article we discuss several issues relevant to employers.



IRS Provides Guidance on QSEHRAs

On October 31, 2017, the IRS provided the first comprehensive guidance on Qualified Small Employer Health Reimbursement Arrangements (“QSEHRAs”) in Notice 2017-67. This new guidance is effective for plan years that begin on or after November 20, 2017.



Questions and Answers for Employers

Please click on the 'Read More' link below to access our healthcare reform FAQs for employers.


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