If certain requirements are met, Notice 2018-88 proposes that offering an individual coverage HRA would generally:
The IRS began issuing Letter 226-J to ALEs in late 2018 to propose and assess employer shared responsibility penalty liability for the 2016 calendar year.
Several ACA requirements will be affected by changes that take effect in 2019, such as increased dollar limits and affordability percentages. To prepare for 2019, employers should review upcoming requirements and develop a compliance strategy. This ACA Overview provides an ACA compliance checklist for 2019.
On Nov. 5, 2018, the IRS published Notice 2018-85, which provides the adjusted PCORI fee amount for plan years ending on or after Oct. 1, 2018, and before Oct. 1, 2019 (that is, 2018 for calendar year plans). As this ACA Compliance Bulletin notes, for plan years ending on or after Oct. 1, 2018, and before Oct. 1, 2019, the PCORI fee amount is $2.45 multiplied by the average number of lives covered under the plan.
This month’s Benefits Buzz provides an overview of the ACA hardship exemption for 2018, discusses IRS letters being sent to noncompliant employers and teases the possibility of an overtime rule update starting next year. Update: the Did You Know section was revised for the adjusted overtime implementation timeline.
The proposed rule would allow HRAs to be integrated with individual insurance policies. The rule would also allow
employers to offer an excepted benefit HRA with traditional group coverage. Specific requirements would apply to both types of HRAs.
This month's Benefits Buzz discusses the guidance on association health plans issued by the IRS and Department of Labor, provides a reminder that Medicare Part D notices are due Oct. 15 and explains the repeal of the individual mandate penalty.
The IRS released final 2018 forms and instructions for ACA reporting under Code Sections 6055 and 6056. The 2018 forms and instructions are substantially similar to the 2017 versions. This ACA Compliance Bulletin provides an overview of the forms and instructions.
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