What follows is a summary of a report composed by a few of my colleagues. The full report is very detailed, but it is worth reading if you have the time to sit and digest it at length. Check out the Executive Summary (below), and find the entire Alert here.
- Congress yesterday morning passed a repeal of the enhanced Form 1099 filing requirement imposed by last year’s healthcare reform law, the Patient Protection and Affordable Care Act of 2010 (PPACA). The filing obligation would have required businesses to report on a Form 1099 the amounts paid to every supplier of goods and services who received at least $600 from the employer over the course of the taxable year. The filing obligation would have applied beginning next year.
- Federal authorities have issued additional guidance on the PPACA’s “grandfathered plan” rules, supplying more flexibility to plans seeking to avoid loss of grandfathered status. Plans may avoid loss of grandfathered status when transferring employees from one coverage option to another, in a variety of circumstances; imposing additional cost sharing on prescription drugs once a generic equivalent is available; and installing new cost sharing requirements in a manner consistent with reasonable “value-based insurance designs.”
- Federal regulators have deferred compliance deadlines for certain changes to a health plan’s claims and appeals process, as required by PPACA.
- The IRS issued 19 pages of guidance on PPACA’s requirement that employers begin to report health plan coverage values on the Form W-2. The guidance defers indefinitely the effective date of the reporting obligation for certain small employers, clarifies the nature of health coverage that must be reported and how to calculate the cost of the coverage, and spells out additional details regarding how the reporting requirement applies in certain routine contexts, such as where there are multiple employers with a common paymaster.
- The $5 billion Early Retiree Reinsurance Program (ERRP) created by the health reform bill will stop accepting applications early next month, and is expected to exhaust its funds later this year or early next year.
- Federal authorities issued a series of Frequently Asked Questions related to the new federal long-term care insurance entitlement program known as “CLASS.” The FAQs make clear that employer involvement is voluntary.