If not, you are likely not alone but need to get it posted because the deadline for posting was October 16th. In an earlier blog post, we discussed what entities may be “covered entities” and subject to the new Section 1557 nondiscrimination rules of the ACA. If you have determined that you are a covered entity subject to ...
Just when you think you have heard it all, HIPAA has a requirement that plan sponsors must send a notice to participants letting them know they have a right to receive a notice of privacy practices. But first, let’s take a step back. HIPAA requires that group health plans distribute a notice of privacy practices to all newly ...
Section 1557 is a new anti-discrimination section added by the ACA that prohibits in certain health programs and activities discrimination on the basis of race, color, national origin, sex, age or disability. At first, the new provision did not receive much attention because we believe some companies saw it and thought “of course we ...
By David Pixley
Under Firestone, a U.S. Supreme Court Case decided in 1989, plan administrators are entitled to a deferential standard of review, but only if such authority is expressly reserved in the plan documents. Absent sufficient language in the plan documents, the trial court will conduct a de novo review (no deference given to the plan ...
Of course a HIPAA breach is bad news for any covered entity, but when there are three breaches in a row, it’s not just bad news – it’s a pattern. In three separate breach reports filed with HHS in a three-month period, Advocate Health Care Network disclosed that: (1) four desktop computers containing PHI of about 4 million patients ...
On July 29, 2016, the IRS issued proposed regulations that provide some further guidance for anxious employers that are required to file information returns, Forms 1094/1095.
Under tax code section 6055, which was added by the ACA, employers are required to file information returns and provide taxpayer identification ...
Failing to comply with ERISA can cost you. Under the DOL’s interim final rule, beginning on August 1, 2016 those same failures could cost you more, much more. It has been many years, decades in some instances, since these penalties were last adjusted for inflation. Beginning in 2017, the DOL is expected to make annual adjustments ...
Recently, the IRS provided further guidance for employers that are attempting to electronically file Forms 1094/1095. Specifically, the IRS will continue to accept returns for 2015 that are filed after the June 30th electronic filing deadline through the Affordable Care Act Information Returns (“AIR”) Program. If your ...
The Form 1095-C is new to most employers, but it’s important to remember that it’s also new to your employees. This Form may cause some confusion on the part of some of your employees. Therefore, the first step should be to verify whether the Form 1095-C is incorrect or if the employee is merely confused about the information ...
We have received multiple calls from panicked clients in the past several days due to the clients receiving Health Insurance Marketplace Notices from HHS. If you received one of these notices, please don’t panic quite yet. It does not necessarily mean that your company is subject to a shared responsibility penalty. You ...