Recent written audit requests to health and welfare plans from the U.S. Department of Labor (DOL) have included inquiries related to various mandates under the Affordable Care Act (the ACA or the Act). This is a significant development in the ongoing implementation of the ACA’s various coverage and related mandates, in that it marks the first appearance of ACA-related topics in DOL auditing practices. While the recent U.S. Supreme Court oral arguments caused speculation as to the future of the ACA, unless and until the ACA is ruled unconstitutional by the Supreme Court, the Act is enforceable and will be enforced by the DOL. Thus, employer-provided group health plans must continue to comply and otherwise implement the ACA’s various coverage and related mandates.
| IRS Clarifies Previous Guidance on Form W-2 Informational Reporting Requirement
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.
| SIG Names Christi Spackman Senior Account Manager
Christi Spackman has been named a Senior Account Manager with Silberstein Insurance Group (SIG). Spackman comes to SIG from Group Benefit Services, where she was a broker consultant.
At SIG, Spackman will provide strategic account development and support for group clients of all sizes.
| SIG Names Robert C. Harnett VP
Robert C. Harnett has joined Silberstein Insurance Group (SIG) as Vice President. In his new position, Harnett will be responsible for management and delivery of SIG’s products and services to middle and large market clients.
With an extensive background in health and welfare programs, risk management, alternative plan financing, benefit plan design, ERISA plan compliance, and healthcare delivery system formation, Harnett holds licenses for all lines of insurance coverage in multiple states.
| 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).