Highlighted Posts

David M. Pixley

Union employers that contribute to multiemployer plans should proceed with caution when hiring non-union subcontractors. Union employers are obligated to make contributions to various benefit funds for their own employees, but what about for subcontractors? Under some collective bargaining agreements (CBAs), if the  ...
Lyndsey R. Barnett

As 2016 edges closer, the monthly and lookback measurements are a reality rather than just material for seminars. Even employers who are well educated on the process are likely to have situations come up that they hadn’t thought about how to handle under the ACA. One of these types of situations that we have received some  ...
Lyndsey R. Barnett  

We previously wrote about offering coverage to interns, and now as the January 31st Form 1094/1095 deadline rapidly approaches, clients have started asking a logical follow-up question:  ok, so I have to offer coverage if they work full-time and satisfy our waiting period, but do I have to report them as a full-time employee?   

Lyndsey R. Barnett 

As the end-of-year notice season rolls along, keep in mind that you have a few more deadlines looming if you sponsor a retirement plan with a January 1st plan year and your plan contains any of the following features:  

401(k) Safe Harbor Notice
If your plan is designed as a safe harbor plan to avoid ADP and/or ACP testing, you must send ...
David M. Pixley

The President signed the Bipartisan Budget Act of 2015, which in part, repealed a provision of the Affordable Care Act (ACA). Under the ACA, employers with more than 200 full-time employees would have been required to automatically enroll new full-time employees in one of the employers’ health benefits plans. Implementation of ...
Lyndsey Barnett 

As open enrollment season rolls along for most calendar year health plans, we know that you have enough to worry about without throwing another form into the mix. However, if you are a large employer (50 or more full-time equivalent employees) and you don’t require employees who waive coverage to sign a formal waiver, maybe ...
Lyndsey R. Barnett

When I see the foliage changing every fall, it always reminds me of the IRS’s annual update to the retirement plan limits. The IRS adjusted most of the relevant limits last year (please ignore the reference in last year’s article about the Bengals disappointing  – not this season!). This year, there was almost no ...
Jamie D. Scott

HIPAA privacy and security breaches have been a hot item in the news this year thanks to the publicity surrounding the Anthem hacks.  All of the publicity has increased public awareness regarding HIPAA breaches and has put significant pressure on the Department of Health and Human Services’ Office of Civil Rights (“OCR” ...

Like many other employers, there is a good chance you are currently focused on implementing open enrollment for next year. However, the end-of year notice season is rapidly approaching, and the Medicare Part D Creditable Coverage Notice is first on the list. You must issue this notice to all individuals enrolled or seeking to enroll in your ...
Lyndsey Barnett 

There is a lot of confusion as to whether an employer with a Health Reimbursement Arrangement (“HRA”) must report the employees participating in the HRA on Form 1095. Part of the confusion stems from the fact that the IRS keeps changing its mind.    

In the final draft of the 2015 Instructions for Forms 1094-B and 1095-B , the IRS  ...

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