On January 3, 2012, the Internal Revenue Service (“IRS”) released Notice 2012-9, which restates and clarifies its prior guidance on the requirement under the Affordable Care Act to report the cost of employer-sponsored health coverage on employees’ annual Forms W-2 (using box 12, code DD). Notice 2012-9 supersedes the prior guidance issued under Notice 2011-28 and clarifies various aspects of the reporting requirement.
| U.S. Department of Labor FAQ #7 Delays Summary of Benefits and Coverage Requirements under ACA
The U.S. Department of Labor (DOL) recently published the seventh installment of a series of answers to Frequently Asked Questions regarding implementation of the Affordable Care Act and the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).
| Guidance Released on Uniform Summary of Benefits and Coverage
The Departments of Labor, Health and Human Services, and the Treasury recently released proposed regulations that provide standards for use by group health plans and health insurance carriers in compiling and providing a summary of benefits and coverage (SBC) and a uniform glossary of commonly used health insurance and medical terms, as required by the Affordable Care Act. The Departments also released templates, instructions and related materials to assist with development of the SBC and disclosure of the uniform glossary. Read this alert to learn more about this initiative.
| Women's Health Preventive Care Requirements
Earlier this week, the Department of Health and Human Services (HHS) issued detailed guidelines regarding women’s health care services that group health plans and health insurance policies must cover without cost-sharing pursuant to Section 2713 of the Patient Protection and Affordable Care Act, as amended (ACA). These guidelines amend and supplement the interim final rules relating to coverage of preventive services that were issued on July 19, 2010 (the Preventive Care Interim Final Rules).
| Section 125 Plans May Need to be Amended by July 1
As discussed more fully in the September 28, 2010 client alert provided by our Compliance Director and Proskauer (Changes on Over-the-Counter Drug Coverage Required Under Health Care Reform in 2011) and mentioned again in the May 9, 2011 client alert (Health Reform Update: Recent Changes and Challenges to the Affordable Care Act), IRS Notice 2010-59 provides that over-the-counter medicines or drugs purchased without a prescription on or after January 1, 2011 (other than insulin) may no longer be paid for or reimbursed under account-based plans, such as health FSAs, HRAs, and HSAs.