ACA
Individual Coverage Health Reimbursement Arrangements (ICHRAs) first became available in 2020. ICHRAs allow employers to reimburse employees for individual health insurance coverage (or Medicare coverage) that employees obtain on their own. ICHRAs provide employers with an alternative to offering traditional group health insurance coverage to employees.
As we approach the new year, it is important that employers and benefit advisors not forgot some of the reporting obligations that come along with offering group health plans and other employee benefit programs.
Here are four reporting reminders:
The Affordable Care Act (ACA) created two reporting requirements which are spelled out in Internal Revenue Code Sections 6055 and 6056.
Section 6055 requires every provider of minimum essential coverage to report information of those employees and dependents who enroll in coverage. Reporting this information to the Internal Revenue Service (IRS) is still required even though the Individual Shared Responsibility penalty (i.e. Individual Mandate) is $0.
The Supreme Court of the United States (SCOTUS) is scheduled to hear oral arguments about the constitutionality of the Affordable Care Act (ACA) today. The underlying issue to be heard is whether the elimination of the Individual Mandate penalty now invalidates some, all, or none of the law. One of the following outcomes is likely to occur:
The Employer Mandate guidelines state that coverage is affordable when an employee has to pay no more than 9.5% of their household income (inflation-adjusted to 9.83% for the 2021 plan year) for self-only coverage which is offered, but which employers know the household income of an employee? As a result, there are three alternative methods that an employer can rely upon when determining if the coverage they offer is affordable. These methods are explained below and some general examples of how to apply each method have also been provided.
The Internal Revenue Service (IRS) recently issued Notice 2020-76 with information pertaining to the upcoming reporting required by the Affordable Care Act (ACA).
The following information was included in the notice:
The Internal Revenue Service (IRS) has issued draft reporting forms for the purpose of filing information necessary to enforce the Employer Mandate. The 2020 draft version of the applicable forms can be found below (with finalized versions expected to be released later this year):
A date is finally set for the Supreme Court of the United States (SCOTUS) to once again rule on the constitutionality of the Affordable Care Act (ACA). Oral arguments are expected to be heard on November 10, 2020, just one week after the presidential election.
The Internal Revenue Service (IRS) recently issued Rev. Proc. 2020-36 which includes details on the minimum required contribution percentage in determining whether employer-sponsored health coverage is affordable. In 2021, employer-sponsored health coverage will be considered affordable if an employee has to pay no more than 9.83% (an increase of 0.05% from 2020) of their income for such coverage.
Health Savings Account News
You may have previously heard that the 2019 federal tax filing deadline was extended until July 15, 2020. In the event you were unaware, contributions to Health Savings Accounts (HSAs) for the prior year can be made up until the tax filing deadline. The tax filing extension is impactful to HSAs for two reasons:
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