IRS

Posted May 10th, 2016 in Producers, Employers
What happens to beneficiaries who are enrolled in COBRA when a merger or acquisition occurs?
 
The Internal Revenue Service (IRS) has some rather thorough and complex guidelines that address COBRA issues when business reorganizations occur, including mergers and acquisitions. In an effort to simplify an otherwise complex situation, we can generally break down the guidance as follows:
 
Posted April 11th, 2016 in Producers, Employers
Originally posted on January 2, 2015 and updated on April 10, 2015, June 19, 2015 and April 11, 2016.
 
Posted February 19th, 2016 in Producers, Employers

Premium Only Plans (POP) can generally be defined as a type of Cafeteria Plan where the only pre-tax benefit available to employees are for those of insurance premiums. Now, whenever non-taxable benefits are involved, the IRS will usually have some strict rules in place that must be followed. For Cafeteria Plans, these are referred to as non-discrimination rules, and these rules are in place to ensure the plan doesn’t discriminate in favor of highly compensated and/or key employees.

Posted December 30th, 2015 in Producers, Employers
The Internal Revenue Service (IRS) recently issued Notice 2016-4 which extends the deadlines to complete the new Affordable Care Act (ACA) reporting requirements. The reporting is used to help the IRS enforce the Individual and Employer Mandates, and it’s also used to help the IRS administer subsidies in the Exchange. It applies to insurers and certain employers effective for the 2015 calendar year and moving forward. The new deadlines are as follows:
 
Posted November 13th, 2015 in Producers, Employers

The new reporting requirements that some employers will be subject to starting next year, as required by the Affordable Care Act (ACA), will be used to help the Internal Revenue Service (IRS) enforce the Individual and Employer Mandates, and it will also help the IRS administer subsidy eligibility in the Exchanges.
 

The following reporting forms will be the responsibility of the employer to complete:

Posted October 30th, 2015 in Producers, Employers

PCORI Fees

The Internal Revenue Service (IRS) released Notice 2015-60 on October 9, 2015.  The notice includes information on the payable amounts that are due for the Patient-Centered Outcomes Research Institute fees (PCORI fees). The fee will increase from $2.08 to $2.17 per covered life for plan years ending on or after October 1, 2015 and before October 1, 2016. The next round of PCORI fees will be due by July 31, 2016 for plan years ending in 2015. The payment schedule will be as follows:
Posted August 14th, 2015 in Producers, Employers
It appears that the Internal Revenue Service (IRS) is having some trouble with formulating guidance as it relates to the Excise Tax on High Cost Employer-Sponsored Health Coverage, also known as the Cadillac Tax. Earlier this year the IRS released Notice 2015-16 which sought public comment on the types of coverage that should (or shouldn’t) be included when calculating the value of coverage.  
 
Posted June 19th, 2015 in Producers, Employers, Individuals

What happens to Health and Dependent Care FSAs when a merger or acquisition occurs?  

 
Of course the Cafeteria Plan regulations do not specify how this should be treated, but the IRS has provided some guidance in the form of Revenue Ruling 2002-32. Fortunately, for employees, the IRS has taken a position that employees should not be punished as a result of a merger or acquisition, and the guidance suggests two possible options that would be acceptable in their eyes. Both options maintain the salary reduction of the employee and preserve the annual election.
Posted May 15th, 2015 in Producers, Employers
The third installment of the Patient-Centered Outcomes Research Institute (PCORI) fees will be due on July 31, 2015. As its name suggests, PCORI is a research institute, and it was created by the Affordable Care Act (ACA) as a way to improve clinical effectiveness. It is partially funded by fees charged to health plans. Here is information and some reminders about the upcoming fee that is due.
 
  • The fee is paid on the average number of covered lives for the plan year ending in 2014.

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