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6 results with the tag “IRS”

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Benefits & Healthcare Update: IRS Reminds Employers That Certain Nonmedical Wellness Incentives Are Taxable Income

12 July 2016

The IRS recently released a memorandum reminding employers about the tax treatment of wellness program incentives and employer reimbursement of wellness program-specific premiums. While the memorandum did not break any new ground, it is a useful recap of the IRS rules regarding the taxability of wellness incentives.

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Benefits & Healthcare Update: Departments Release New Guidance on ACA Cost Sharing Limits, HSA Rules

4 May 2016

On Friday April 29, 2016, the Internal Revenue Service (IRS) released HSA contribution rules and HSA-eligible HDHP plan design rules for the 2017 plan year. Previously, the Department of Health and Human Services (HHS) released proposed rules for the out-of-pocket maximum limits applicable to non-grandfathered health plans under the ACA. Remember, there are two sets of rules post-ACA: one regarding out-of-pocket maximum limitations for non-grandfathered group health plans under the ACA, and another set of rules for Health Spending Accounts (HSAs) and HSA-qualifying High Deductible Health Plans (HDHPs) under the Internal Revenue Code. Out-of-pocket Maximum Limitations under ACA For non-grandfathered group health plans, out-of-pocket maximums cannot be greater than $7,150 for single coverage and $14,300 for non-single/family coverage for the 2017 plan year.

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Benefits & Healthcare Update: IRS Increases Affordability Safe Harbors, Clarifies Treatment of Waiver Incentives

13 January 2016

At the end of 2015, the Internal Revenue Service (IRS) provided guidance in Notice 2015-87 with respect to Health Reimbursement Accounts (HRAs) and how to calculate the affordability of coverage. While much of the guidance restates and formalizes previous remarks from the agency, there are a couple new developments in the Notice regarding affordability that can affect the way employers set their employee contributions and structure their plans. Affordability Safe Harbors Indexed In the Final Rule regarding the employer mandate, the IRS established three safe harbors for providing affordable medical insurance to ACA full-time employees: the Federal Poverty Level safe harbor, the Form W-2 safe harbor, and the Rate of Pay safe harbor.

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Benefits & Healthcare Update: IRS Pushes Back Due Date for Form 1095-C to March 31, 2016

29 December 2015

On Monday, December 28th, the Internal Revenue Service (IRS) published Notice 2016-4 announcing transitional relief for health insurance information reporting: Forms 1095-C are now due to individuals by March 31st, 2016 and to the IRS, along with the Form 1094-C, by June 30th, 2016 when filing electronically. This welcome reprieve allows employers and other filing entities more time to establish systems for generating and completing the Forms. Notice 2016-4 can be found on line here: If you have any questions about health insurance information reporting, please contact Ed Doherty at 646-839-8251 or via email at

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Benefits & Healthcare Update: Agencies Finalize ACA Market Reform Rules, Make No Substantial Changes

4 December 2015

On November 18, 2015, the DOL, HHS, and IRS jointly published final rules on grandfathered plan status, pre-existing condition exclusions, lifetime and annual limits, rescissions, dependent coverage, appeals, and patient protections. The final rules formalize and merge the previously issued interim rules and sub-regulatory guidance.

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Benefits & Healthcare Update: IRS Publishes Final 2015 Instructions for Health Insurance Information Reporting

1 October 2015

On September 18, 2015, the Internal Revenue Service (IRS) published the final 2015 instructions for completing Forms 1094-C and 1095-C. The 2015 instructions clarify the reporting of multiemployer plan coverage, make a substantive change in the manner in which offers of COBRA coverage are reported, and clarify how employers report HRA coverage paired with insured medical benefits.

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