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Affordable Care Act
Nothing written by SPBA is legal advice.
90-Day Waiting Period
Articles and Materials
90 Day Waiting Period Final Rules
(1/13/24)
New Rules on 90-Day Waiting Period
(1/13/24)
Official Source Documents
90-Day Waiting Period - Final Rule (Federal Register - February 24, 2014)
(2/24/14)
90-Day Waiting Period - Proposed Rule - Orientation Periods (Federal Register - February 24, 2014)
(2/24/14)
Waiting Period Limitation: Federal Register Proposed Rule
(3/22/13)
Important
Articles and Materials
You ARE an "Employer Sponsored Plan" under ACA
(2/21/13)
PPACA: Health Reform Questions & Answers
(9/12/12)
Q & As to Test Your Knowledge of Health Care Reform
(6/3/11)
PPACA Reg Writers Answer SPBA Questions (Fall 2010)
(11/16/10)
PPACA Reg Writers Answer SPBA Questions
(10/29/10)
Official Source Documents
Federal Register: November 26 2014 (ACA)
(12/2/14)
Self-Compliance Tool for Part 7 of ERISA: Health Care-Related Provisions
(12/2/14)
DOL Compliance Assistance Guide
(11/20/14)
IRS FAQs on Automatic Enrollment, Employer Shared Responsibility and Waiting Periods
(2/9/12)
Health Reform Law
Articles and Materials
Court In ACA Case Imposes ERISA Responsibilities on Plan Sponsor and TPA.
(1/30/23)
ACA: Accidental Birth Explains the Law's Illogic Today
(5/22/13)
PPACA Time Line Advisory (for Webinar)
(5/7/10)
Heath Care Reform: A Perspective Through the Eyes of a Group Health Plan (ppt for webinar)
(5/7/10)
Official Source Documents
Keeping the Affordable Care Act Promise (Bill)
(11/15/13)
The Second Package of the Health Care Reform Law (statutory language) (pdf format)
(4/7/10)
Health Reform Bill Passed by House & Senate (Actual Bill) pdf format
(3/22/10)
ACOs (Accountable Care Organizations)
Official Source Documents
ACO Proposed Regs: Federal Register April 7, 2011
(4/15/11)
Administrative Simplification
Articles and Materials
HIPAA Operating Rules Survey + Free Webinar
(5/27/15)
Issues for TPAs regarding HIPAA First EDI Certification
(3/26/14)
New ACA Proposed Rule on EFT Certification
(2/27/14)
HIPAA – Administration Simplification
(1/30/14)
HHS issues Health Identifier Rule and Formally Delays ICD 10
(4/18/12)
HHS Regulations Adopt Standards for HIPAA Electronic Funds Transfers
(1/27/12)
Health Reform Changes to EDI (ppt. from Webinar)
(9/2/11)
New Rules on EDI
(7/12/11)
Official Source Documents
Rescinding HPID Requirement Final Rule 2019
(11/1/19)
Clarifying Questions and Answers Related to the July 6, 2015 CMS/AMA Joint Announcement and Guidance Regarding ICD-10 Flexibilities
(7/29/15)
CMS-AMA ICD-10 Flexibilities Statement
(7/29/15)
ICD-10 - Testing with CMS
(7/29/15)
Administration Simplification: Certification of Compliance Proposed Rule for Health Plans: Federal Register January 2, 2014
(1/2/14)
IFR on Administrative Simplification (HHS: a pdf document)
(7/13/11)
Anti-Fraud
Articles and Materials
Health Care Reform Anti-Fraud Sleepers
(12/21/10)
AHPs (Association Health Plans)
Official Source Documents
Presidential Executive Order Promoting Healthcare Choice & Competition
(8/13/19)
Associated Health Plans & DOL (Case)
(3/29/19)
AHP: ERISA Compliance Assistance
(10/22/18)
Q&As on Employer Shared Responsibility Provisions Under the ACA
(8/22/18)
Annual and Lifetime Limits
Articles and Materials
Annual and Lifetime Limits: Reg Writers Provide Insights on PPACA Issues
(11/15/24)
More on Annual and Lifetime Limits (Email)
(1/13/24)
Prohibition on Lifetime and Annual Limits (Article)
(5/13/10)
Official Source Documents
Annual and Lifetime Limits (Federal Register): Preexisting Condition Exclusions, Patient Protections (primary care physician choice, emergency services), Rescissions
(6/29/10)
Fact Sheet on Patient Protection Annual Limits (Email)
(6/22/10)
Auto Enrollment
Articles and Materials
Auto Enrollment
(11/4/15)
Auto-enrollment Rules for Employers with Over 200 Employees
(12/21/10)
Official Source Documents
DOL Technical Release: No. 2012-01 - Auto Enrollment
(7/12/13)
Cadillac Tax
Articles and Materials
Spending Bill Reauthorizes PCORI, Repeals Cadillac Tax
(1/3/20)
Cadillac Tax Delay
(1/29/18)
Cadillac Tax Delayed Until 2020
(5/17/17)
Excise Tax Comments from SPBA
(5/21/15)
Excise Tax (Slides from Webinar: Latest Developments & Looking Ahead)
(3/13/13)
Official Source Documents
IRS Second Notice (2015-52) on Excise Tax on High Cost Plans
(7/31/15)
Statute of Excise Tax on High Cost Employer Sponsored Health Coverage
(5/8/15)
Congressional Report on Explanation of Cadillac Tax
(5/8/15)
IRS Notice on Excise Tax on High Cost Coverage
(2/24/15)
Cases
Articles and Materials
Defense of Marriage Act Headed to Supreme Court
(6/1/12)
Official Source Documents
Order from Florida Court on Obamacare
(2/7/11)
Webinar
Webinar: The Chevron Decision: What You Need To Know
(8/2/24)
Claims
Articles and Materials
Schedule J Proposed in New 5500 Regulations
(12/5/16)
Official Source Documents
Claims Regs - Final Rules: 2015-29294
(12/28/15)
Claims and Appeals/External Review
Articles and Materials
Benefit Claims, Appeals and External Review Deadlines
(8/17/11)
Revised Model Notices, and Guidance on Internal Claims and External Review
(7/12/11)
Agencies Release New External Review Technical Release
(6/23/11)
Revised Model Notice of Final Internal Adverse Benefit Determination - Revised as of 6-22-11
(6/23/11)
States with Consumer Assistance Programs under PHS Act Section 2793 - Current as of 5-23-11
(6/23/11)
Benefit Claims, Appeals and External Review Timeline
(6/20/11)
DOL Extends enforcement of Internal Claims and Appeals Rules
(3/21/11)
Internal Claims/Appeals & External Review Processes Fall 2010 Meeting Notes
(11/9/10)
Grace Period for Internal Claims & Appeals; DOL Technical Release 2010-02
(11/3/10)
Model Notices on Federal External Review Procedures for Self-Funded Plans
(9/1/10)
Internal Claims/Appeals and External Review Processes under PPACA and its Companion Bill, The Health Care and Education Reconciliation Act of 2010 and its Model Notices
(8/17/10)
Interim Final Regs on Internal Claims & Appeals & External-Review Requirements (E-mail Alert/Article)
(7/22/10)
Interim Final Rules for Claims & Appeals & External Review Processes (statutory language)
(7/22/10)
Uniform Health Carrier External Review Act (statutory language)
(7/22/10)
Official Source Documents
DOL Technical Release: Extension of External Review Process 2013-01
(3/20/13)
Rules Relating to Internal Claims & Appeals & External Review Process: Amendment to Interim Final Rules with Request for Comments
(6/23/11)
Technical Release 2011-02: Guidance on External Reviews
(6/23/11)
Regulations for Internal Claims & Appeals Effective Date Extended + Technical Release 2011-01
(3/18/11)
Federal External Review Process: Request for Information (Federal Register 11/17/10)
(11/18/10)
DOL Technical Release 2010-02/Interim Procedures
(10/25/10)
CLASS
Articles and Materials
CLAS County Data + List of Counties (Edition Date: December 2014)
(1/30/15)
CLASS Act - Payroll Deductions NOT Required in 2011
(9/29/10)
Clinical Trials
Articles and Materials
ACA FAQs (Part 31) Clinical Trials & MHPAEA
(4/27/16)
Clinical Trials
(5/28/13)
Cost Sharing
Articles and Materials
HHS Addresses Permissible Employee Cost Sharing under Group Health Plans
(12/13/24)
New Proposed Rules on EHB and Cost Sharing for plan year 2016
(1/8/15)
JCEB Meeting with Agencies on Taxation (May Meeting 2013)
(8/12/13)
HHS Issues Proposed Regulations on Essential Health Benefits
(12/19/12)
Official Source Documents
Standards Related to Essential Health Benefits, Actuarial Value & Accreditation; Final Rule (Federal Register)
(8/16/13)
Cures Act
Articles and Materials
New IRS & Treasury FAQs On QSEHRAs
(11/28/17)
Official Source Documents
Qualified Small Employer Health Reimbursement Arrangements
(11/15/17)
Dental Plans
Articles and Materials
Dental Plans and Health Care Reform
(11/3/10)
"Excepted Benefits" and Health Care Reform
(9/29/10)
Dental Plans and Dependent Coverage of Children to Age 26
(5/13/10)
Dependent Coverage
Articles and Materials
Dependent Coverage to Age 26 and Active Duty
(2/13/24)
DOL Q & A on Grandchildren Dependency Factors
(6/5/22)
Dependent Child Coverage Questions Posed by SPBA Members
(6/10/10)
IRS Guidance on Tax-Free Employer-Provided Health Coverage for Dependent Children
(5/13/10)
Agencies Release Interim Final Rules on Dependent Coverage of Children to Age 26 (Email Alert)
(5/10/10)
Interim Final Rules on Dependent Coverage of Children Released (Email Alert)
(5/10/10)
Official Source Documents
Interim Final Rules on Dependent Coverage of Children to Age 26 Fact Sheet
(5/1/15)
Interim Final Rules on Dependent Coverage of Children to Age 26 (pdf)
(5/11/10)
IRS Notice 2010-38 on Tax Treatment of Health Care Benefits to Children Under Age 27
(4/29/10)
Early Retiree Reinsurance Program
Articles and Materials
ERRP New Guidance
(8/17/11)
ERRP Clarification
(8/17/11)
Early Retiree Program Issues New Q/A/ and Reminders
(6/3/11)
ERRP Update
(12/21/10)
DOL News: Trusts & Confidential Communications
(12/21/10)
ERRP Application
(8/18/10)
The ERRP Application is Now Officially Available for Filing
(6/29/10)
HHS Releases Draft Application for Early Retiree Claims Subsidy
(6/4/10)
Early Retirees in the Affordable Care Act
(5/14/10)
Health Care Reform: Early Retirees in the Affordable Care Act
(5/7/10)
Early Retirees in the Affordable Care Act (Email Alert)
(5/5/10)
Official Source Documents
CMS to Stop Accepting Applications; ERRP - Federal Register Reg
(4/5/11)
CMS to Stop Accepting Applications - ERRP
(4/5/11)
CMS Posts New Version of ERRP Application + Dos & Don'ts
(11/5/10)
Early Retiree Reinsurance Program Application etc.
(6/29/10)
Early Retiree Reinsurance Program - Federal Register, May 4, 2010
(5/5/10)
Reinsurance Program for Early Retirees (Temporary)
(4/27/10)
HHS Reinsurance Fact Sheet
(4/8/10)
Employer Shared Responsibility
Issues to Consider When Designing Compliant Non-Major Medical Minimum Essential Coverage Plans (Webinar)
(3/27/14)
Articles and Materials
Are ALEs Required to hold Open Enrollment Periods?
(1/3/20)
IRS Extends 2019 ACA Reporting Deadlines
(1/3/20)
IRS Releases ACA Affordability Rates for 2020 + Rev. Proc 2019-29
(8/6/19)
Employer Shared Responsibility Penalties for 2019
(2/12/19)
Marketplace Appeal Letters
(8/30/16)
A Variable Hour Employee/Measurement Issues
(7/25/15)
Dependent PTC and Impact on ESR Payment
(6/27/15)
Documentation of Coverage Offer
(9/29/14)
The SPBA Manual to the Pay or Play Rules (Updated November 26, 2014)
(7/11/14)
TRANSITION RELIEF for Employer Shared Responsibility
(2/27/14)
Cafeteria Plan Elections and Going to the Exchange
(10/24/13)
Non-Major Medical Plan and MEC
(10/24/13)
Will Changing a Plan's Renewal Date Delay Compliance with ACA?
(5/31/13)
Play or Pay in 2014 (Shared Responsibility for Employers Regarding Health Coverage)
(1/2/13)
Employer Penalties and Issues to Watch For
(9/14/12)
Minimum Value of an Employer-Sponsored Health Plan
(5/29/12)
Health Care Reform: Employer Mandate and Federal Subsidies
(8/17/11)
Official Source Documents
IRS Memo on ESR Penalty Statute of Limitations
(3/13/20)
ESRP Response + Employee Premium Tax Credit (PTC) Listing: Forms 14764 + 14765
(12/6/17)
IRS Letter on Calculating ESR Liability
(11/13/17)
IRS Notice 2015-87: Variety of ACA Related Provisions
(12/17/15)
IRS Notice on Proposed Approach to Look-Back Measurement
(9/19/14)
Play or Pay 2014 Final Rules (Single Column)
(3/1/14)
Notice 2013-45: Transition Relief for 2014
(7/10/13)
Play or Pay 2013 Rules: Federal Register Proposed Rules
(1/2/13)
Play or Pay 2013 IRS Q&As
(1/2/13)
IRS Notice 2012-31 on Minimum Value of Employer-Sponsored Health Plan
(12/7/12)
IRS Notice 2012-58 - Determining Full-Time Employees
(9/4/12)
IRS Notice 2012-59 - Guidance on 90 Day Waiting Period Limitation
(9/4/12)
Essential Health Benefits
Articles and Materials
HHS sends RFI to Update Essential Health Benefits
(1/31/23)
HHS Has Released the Essential Health Benefits Bulletin: How Does it Affect Group Health Plans?
(12/20/11)
IOM Issues Report on Essential Health Benefits under Health Care Reform
(10/31/11)
Announcement of IHB IOM Report
(10/7/11)
DOL's Essential Health Benefits Report
(6/3/11)
Reprint of February 22nd Email Concerning Comments on Essential Benefits
(4/14/11)
Reprint of February 22, 2011 Email: Essential Health Benefits
(3/9/11)
Essential Benefits & Task of Crafting Definition
(2/22/11)
Essential Health Benefits
(1/21/11)
Essential Health Benefits
(1/14/11)
Official Source Documents
HHS's Propsed Regulations on Essential Health Benefits: Federal Register
(12/20/12)
HHS Releases the Essential Health Benefits Bulletin
(12/16/11)
Essential Health Benefits: Balancing Coverage and Cost Report
(10/7/11)
Excepted Benefits
Articles and Materials
Amendments to "Excepted Benefits"
(10/24/14)
HHS Issues Essential Health Benefit FAQs
(2/24/12)
"Excepted Benefits" and Health Care Reform
(9/29/10)
Dental Plans and Dependent Coverage of Children to Age 26
(5/13/10)
Official Source Documents
Amendments to Excepted Benefits: Federal Register Proposed Rules December 24, 2013
(12/27/13)
Exchanges
Articles and Materials
Exchange Premiums for Individual Shared Responsibility
(1/29/15)
Transitional Reinsurance Fee, Exchanges & SHOP
(2/27/14)
Should You Reconsider Giving FLSA Exchange Notices Given New DOL Guidance?
(9/13/13)
Updated: September 12, 2013: Exchange Notice: No Penalties for Noncompliance
(9/12/13)
FAQs: Notice of Coverage Options (Updated 9-12-13)
(9/12/13)
Penalties for Noncompliance
(9/11/13)
Employers Prepare for Exchange Verification of Employer-Sponsored Coverage
(9/5/13)
Myth vs. Fact: Health Insurance Marketplace on Track
(8/2/13)
Exchange Regs Impact Employer Verification Requirements
(7/10/13)
Pay or Play Delayed for One Year, The Exchange Notice was NOT Delayed
(7/8/13)
SPBA FAQs: State Exchange Model Notices
(5/28/13)
Department of Labor Releases Exchange Notice (Exchange Notices, Guidance & COBRA Election Notice)
(5/9/13)
Exchange News
(5/3/13)
SHOP and Exchanges Update
(4/26/13)
Small Business (SHOP) Exchange Delayed (Corrected)
(4/3/13)
Marketplace: Video Description and URL
(3/25/13)
New Exchange Regulations Include Exemptions to Individual Shared Responsibility Provision
(2/4/13)
Exchange Notice Delayed
(1/28/13)
State Exchange Notifications to Employees
(1/18/13)
Exchange Enrollment Process
(1/14/13)
Exchange Rules Released
(3/13/12)
Comments on Exchanges
(10/5/11)
Fate of State Exchanges
(7/12/11)
HHS Releases Proposed Rules On Exchanges
(7/12/11)
Exchanges as 1st Priority
(8/17/10)
Official Source Documents
FINAL 2016 Letter to Issuers In the Federally-facilitated Marketpalces
(2/23/15)
HHS Notice of Benefit & Payment Parameters for 2016
(2/23/15)
IRS Revenue Procedure 2015-15
(1/30/15)
FAQs: Payment Process for January 2014
(10/23/13)
FAQs: Agent & Broker Frequently Asked Questions
(10/4/13)
FAQs: FF-SHOP Issuer Frequently Asked Question
(10/4/13)
Affordable Insurance Exchanges Guidance: Members of Congress & Staff Accessing Coverage through Marketplaces
(10/1/13)
FAQs: Affordable Care Act Implementation (Part XVI)
(9/9/13)
CMS Guidance on Clarifying Income Verification on Exchanges
(8/12/13)
Employer Coverage Tool
(8/1/13)
CMS Navigator Assistance Roles
(8/1/13)
Exchange Regs: Standards for Navigators and Assisters (Final Rule)
(7/26/13)
HHS Final Rule on Exchange Verification
(7/10/13)
NAIC Consumer Information Subgroup, Exchanges, Flow Chart etc.
(4/17/13)
CCIIO Letter to Exchanges
(4/8/13)
Marketplace: Non FA Paper Application
(3/25/13)
Marketplace Individual Questionnaire
(3/25/13)
Marketplace: FA Paper Application
(3/25/13)
Marketplace: Individual Application Supporting Statement
(3/25/13)
Exchange Rules
(2/1/13)
HHS Proposed Rule: Exchange Eligibility Appeals and Other Provisions Related to Eligibility & Enrollment for Exchanges
(1/14/13)
Establishment of Exchanges & Qualified Health Plans; Exchange Standards for Employees
(3/13/12)
FAQs Implementation
Official Source Documents
DOL EBSA Webpage of ACA FAQs
(8/1/23)
FSAs
Articles and Materials
IRS Releases 2019 FSA Inflation Adjustment
(11/15/18)
Comment Letter on the $2,500 Limit on Health FSAs
(7/17/12)
Official Source Documents
Section 125 - Cafeteria Plans (Notice 2012-40)
(5/31/12)
Grandfathered Plans
Articles and Materials
What Happens When Grandfathered Status is Lost
(6/5/22)
DOL Clarifies Contribution Rate Changes to Grandfather Rule
(6/5/22)
Final Rule on Grandfathered Health Plans Amends Some Cost Sharing Requirements
(12/30/20)
DOL Clarifies Contribution Rate Changes to the Grandfather Rule
(9/27/11)
Amendment to Grandfather Rules & Waiver Limits
(11/16/10)
Expendable Grandfather
(8/17/10)
Agency Grandfather Table
(8/2/10)
Grandfathered Interim Final Rules- A Detailed Look
(7/12/10)
Grandfathered Interim Final Rules - First Look
(6/15/10)
What is the Benefit of Being a Grandfathered Plan?
(6/14/10)
Official Source Documents
Grandfathered Group Health Plans & Grandfathered Group Health Insurance Coverage
(2/26/19)
Amendment to the Grandfather Interim Rule (pdf)
(12/8/10)
Grandfathered Plans Interim Final Rules
(6/14/10)
Health Reform Impacts and Trends
Articles and Materials
The Number of "Uninsured": Past and Future
(1/17/12)
HRAs (Health Reimbursement Accounts)
Articles and Materials
Chart and Summary of ACA Premium Reimbursement HRA Guidance
(11/27/13)
Deductible Caps on Small Business
(4/26/13)
Deductible Caps on Small Business Health Plans
(3/21/13)
Official Source Documents
IRS Guidance on Small Employer HRAs (IRS Notice 2017-67)
(11/2/17)
Health Coverage Reimbursement Arrangements- IRS Notice 2015-17
(2/18/15)
HRA Annual Limit Waiver Guidelines
(10/4/13)
Technical Release 2013-03
(10/4/13)
HSAs (Health Savings Accounts)
Articles and Materials
IRS Releases HSA Inflation Adjusted Amounts for 2025
(5/28/24)
Adult Dependents and HSAs
(12/21/10)
Official Source Documents
IRS Rev. Proc. 2018-27 (2018 HSA Deductions)
(4/27/18)
Mandated Claims Appeals
Articles and Materials
Mandated Claims Appeals Processes
(4/27/10)
Medical Loss Ratio
Articles and Materials
Medical Loss Ratio Provision in Health Reform
(5/13/10)
Official Source Documents
Fact Sheet: Middle Class Americans Saving Billions Under the Health Care Law's Medical Loss Ratio Refunds
(7/29/13)
MHPAEA
Articles and Materials
Report to Congress on MHPAEA Released by Federal Agencies
(2/27/25)
SPBA Meets with Agencies on MHPAEA Compliance
(12/14/22)
Agencies Solicit Comments on MHPAEA, Issue Model and FAQs
(6/30/17)
Mental Health Parity Compliance Checklist
(6/29/16)
Mental Health Parity Compliance Checklist
(6/29/16)
ACA FAQs (Part 31) Clinical Trials & MHPAEA
(4/27/16)
MHPAEA and PPACA
(9/29/10)
Official Source Documents
Biden Administration Releases New MHPAEA Regulation
(8/25/23)
Parity of Mental Health & Substance Use Benefits with Other Benefits; Using Your Employer-Sponsored Health Plan to Cover Services
(6/29/16)
Warning Signs-Plan or Policy Non-Quantitative Treatment Limitations that Require Additional Analysis to Determine MHP Compliance
(6/29/16)
DOL MHPAEA Warning Signs: Plan or Policy NQTLs That Require Additional Analysis
(6/22/16)
Determining Mental Health Parity Compliance
(6/2/16)
Mini-Med Waivers
Articles and Materials
Annual Limit Waivers Filing Due
(10/31/12)
Guidance Released by HHS for Annual Limit Waivers
(7/12/11)
Health Reform: Guidance Released by HHS for Annual Limit Waivers
(6/23/11)
Mini-Med Waiver Extension to 12/31/13
(6/20/11)
More Limited Benefit Plan Waiver Guidance- December 2010
(12/13/10)
Amendment to Grandfather Rules & Waiver Limits
(11/16/10)
Mini-Med Waiver : HHS Issues Guidance September 2010
(9/7/10)
Mini-Meds and the Waiver Program
(8/17/10)
Official Source Documents
Technical Instructions for Waivers as of 8/19/2011
(8/24/11)
Guidance: Exemption for Health Reimbursement Arrangements that are Subject to PHS Act Section 2711
(8/24/11)
Supplemental Guidance on Waiver December 2010
(12/13/10)
Sale of New Limited Benefit Plan Guidance
(12/13/10)
Waiver Application Form
(12/13/10)
Waiver Guidance November 2010
(11/16/10)
Mini-Meds Waiver & Annual Limits Guidance & Requirements Sept 2010
(9/7/10)
Minimum Essential Coverage
Articles and Materials
Non-Major Medical Plans and Preventive Services
(11/4/15)
Non-Major Medical Plan and MEC
(10/24/13)
Official Source Documents
Rev. Proc. 2019-29
(7/22/19)
IRS Final Regs MEC
(11/26/14)
CCIIO Guidance on Minimum Essential Coverage
(11/4/13)
Minimum Value
Articles and Materials
CMS Director Comments on Minimum Value at SPBA Meeting
(4/30/15)
Final Rule Minimum Value includes "Substantial Coverage"
(2/26/15)
Gillihan Memo on Minimum Value
(11/12/14)
IRS Proposed Rules on Minimum Value and Wellness Incentives
(5/28/13)
Official Source Documents
HHS Final Rule Minimum Value Released 2-20-2015
(2/22/15)
IRS Proposed Regulation on Minimum Value
(5/3/13)
Minimum Value Calculator under Plan Management Regulations + Minimum Value Calculator Methodology under Plan Management Released on February 20, 2013
(2/25/13)
Model Notices
Official Source Documents
Model notice of Opportunity to Enroll in Connection with Extension of Dependent Coverage to Age 26
(6/29/10)
Model Notice on Lifetime Limits No Longer Applying & Enrollment Opportunity
(6/29/10)
Model Notice on Patient Protections
(6/29/10)
Nondiscrimination - HHS
Articles and Materials
HHS Centers for Medicare & Medicaid Services (CMS) Update Payment Parameters in 2023 Notice
(7/5/22)
HHS Proposes Revisions ACA Section 1557 Rule: Article + Regs + Fact Sheet
(6/6/19)
District Court Injunction on ACA Section 1557
(1/5/17)
Transgender Benefits and Application to Employer Plans
(6/29/16)
HHS Non-Discrimination Regulations
(6/1/16)
Official Source Documents
Section 1557 of the Patient Protection and Affordable Care Act
(7/29/22)
Section 1557 Notice of Proposed Rulemaking
(7/29/22)
Franciscan-Alliance v. Burwell
(1/5/17)
Civil Rights: HHS FAQs: Section 1557 of ACA
(6/29/16)
Nondiscrimination in Health Programs & Activities Proposed Rule: News Release + Fact Sheet + FAQs
(9/9/15)
Opt-Out
Articles and Materials
Reminder on Opt-Out Rules for State and Local Government Plans
(5/3/11)
HHS Releases Guidance on Opt-Out Rules for State and Local Government Plans
(9/23/10)
Official Source Documents
HIPAA Opt-Out Model Election Form
(5/9/11)
HIPAA Opt-Out Model Notice to Participants
(5/9/11)
Over the Counter Drugs (OTC)
Articles and Materials
How Does the Revised Definition of Medical Expenses Relate to OTC Drugs
(1/24/13)
FSA & HRA Debit Cards for OTC Purchases
(12/29/10)
IRS Releases Guidance on OTC Drugs: Issue for Debit Cards
(9/7/10)
Official Source Documents
Questions & Answers on Over-the-Counter Medicines and Drugs (Revised Version - 3/21/12)
(12/1/10)
Over the Counter Drug Notice (IRS)
(9/7/10)
PCORI
Articles and Materials
IRS Releases Updated PCORI Fee
(11/15/22)
IRS Releases Updated PCORI Fee + Form 720 (March 2022)
(1/3/22)
Updated PCORI Released
(11/30/20)
Updated PCORI Fee Released
(6/8/20)
Spending Bill Reauthorizes PCORI, Repeals Cadillac Tax
(1/3/20)
IRS Releases Adjusted PCORTF Fee
(11/6/18)
PICORI Fees
(6/29/18)
PCORI Fees Due on July 31, 2017
(6/26/17)
PCORI Fee - IRS Notice 2016-64
(11/30/16)
PCORI Fee
(2/29/16)
Fees on Plans and Policies for the Patient-Centered Outcomes Research Trust Fund (May 2014)
(5/29/14)
PCORI Questions from SPBA Members
(6/27/13)
PCORI: Q&As
(5/21/13)
Insights on PCORI from Webinar (March 2013)
(5/13/13)
Official Source Documents
IRS Notice 2018-85: PCORI Fee
(11/6/18)
PCORI Fee IRS Notice 2017-61
(10/20/17)
IRS Webpage on Filing Due Dates & Applicable Rates (Link)
(5/4/17)
IRS Webpage on PCORI
(1/5/17)
PCORI Fee - IRS Notice 2016-64
(11/29/16)
PCORI Chart on Types of Coverage (Link)
(11/1/16)
PCORI Fee for 2015- 2016
(11/2/15)
PCORI: Federal Register Final Regulations
(12/10/12)
Penalties
Articles and Materials
Pay or Play Delayed for One Year, The Exchange Notice was NOT Delayed
(7/8/13)
Preventive Services
Articles and Materials
Supreme Court Arguments on Preventive Services Seem to Divide the Court
(4/29/25)
Withdrawal of Preventive Services Proposed Rule on Non-Religious Moral Objections
(2/25/25)
FAQ 68 Preventive Services and WCHRA
(12/17/24)
Proposed OTC Preventive Services Regulations
(12/17/24)
New FAQ 54 Addresses Preventive Services in light of Supreme Court Roe v. Wade Decision
(2/2/23)
Reminder: New and Updated Women’s Preventive Health Services Guidelines Apply in 2023
(2/2/23)
COVID-19 Vaccine Rollout and Payment
(2/2/21)
Supreme Court Allows for Birth Control Exemptions Based on Religious and Moral Objections
(7/8/20)
Final Contraceptives Rules Include Religious and Moral Convictions Exemptions
(12/19/18)
Religious Exemption & Accommodation for Certain Preventive Service Benefits
(10/13/17)
Religious Exemptions and Accommodations for Coverage of Certain Preventive Services under the Affordable Care Act
(10/6/17)
FAQ Part 31 Questions on Preventive and Out-of-Network Emergency Services
(4/27/16)
Preventive Services Final Regulations
(7/29/15)
Preventive Services FAQ Part XXVI
(5/28/15)
The Supreme Court Decision on Hobby Lobby’s Contraceptive Case
(7/31/14)
Religious Contraceptive Issue
(1/30/14)
Final Contraceptive Rules Include TPA Role for Providing Certain Contraceptive Coverage
(7/29/13)
SPBA's Comment Letter to IRS on Contraceptive Coverage
(4/23/13)
Business Associate Agreement & Preventive Contraceptive Services and Self-Insured Religious Plans
(4/17/13)
State Stop-Loss Legislation + HHS Issues Contraceptive Coverage Proposed Rule
(2/4/13)
New Contraceptive Services Guidance Issued
(9/12/12)
Contraceptives and Religious organizations: DOL seeks comments on implementing the preventive care mandate accommodation
(4/18/12)
HHS Releases Interim Final Rule on Women's Preventive Services
(8/2/11)
Preventive Services: Issues Abound - Companion Article: Comments Sought on Plan Design
(2/7/11)
Preventive Services: Issues Abound
(2/7/11)
Comments Sought on Plan Design
(1/21/11)
Preventive Services: Issues Abound
(1/21/11)
Official Source Documents
Withdrawal of Preventive Services Proposed Rule on Non-Religious Moral Objections
(2/11/25)
Testing Price & Preventive - COVID IFC Reg (Federal Register - Nov 6, 2020)
(12/1/20)
HHS Guidance: Revocation of Accommodation Notice
(12/1/17)
Interim Final Rule on Certain Preventive Services under the ACA
(10/6/17)
CMS New Release on 2015 released final regulations for Preventive Services
(7/29/15)
Instructions for Model Notice - Accommodation Notice to HHS
(8/27/14)
Proposed Rule to change definition of Eligibile Organization
(8/27/14)
IFR-Notifying HHS of Accommodation Status
(8/27/14)
Final Rule on Women's Preventive Services regarding Religious Employers Issued - July 2, 2013
(7/8/13)
CMS & CCIIO: Contraceptive Guidance - August 15, 2012
(11/1/12)
Preventive Services Covered under the Affordable Care Act
(7/28/10)
Regulations Released Requiring New Health Insurance Plans to Provide Free Preventive Care
(7/16/10)
Guide to Clinical Preventive Services
(5/27/10)
Reporting
Articles and Materials
IRS Releases Guidance on Affordable Care Act Reporting Requirements
(4/28/25)
At Long Last, Congress Passes Needed ACA Employer Reporting Relief
(12/16/24)
IRS Extends Due Date for ACA Employer Reporting
(12/22/17)
Early DRAFT tax form instructions the 1095B and 1095C
(9/28/17)
ACA Information Reporting Delayed
(11/30/16)
IRS Proposed Rules on MEC Reporting
(8/30/16)
ACA Information Returns Corrections Process
(8/24/16)
IRS Comments on TINs and a Good Faith Effort
(7/15/16)
IRS Video on the ACA Information Returns Corrections Process
(7/15/16)
ACA and US Territories: Do the individual mandate & the employer mandate apply in the US territories?
(2/29/16)
Reporting Offers of Coverage
(1/29/16)
Impact of Measurement Periods on 6056 Reporting
(1/29/16)
Small ALEs Eligible for ACA Employer Mandate Transition Relief Must Still File for 2015
(12/30/15)
Small Extension of Due Dates for ACA ALE and MEC Information Reporting
(12/30/15)
COBRA and 1095-C Reporting
(12/1/15)
1095-C Reporting for Employees on Medicare
(11/4/15)
Multiemployer Plans and ALE Reporting
(11/4/15)
HRA Integrated with Fully Insured ACA Reporting: SPBA Worked the Issue
(9/25/15)
Penalty for Failure To File ACA Employer Reporting
(7/25/15)
No Offer, But Still Report
(6/27/15)
Good Faith Effort Reporting Relief
(6/27/15)
An Overview of Employer/Plan Reporting
(6/27/15)
Can a TPA File Form 1094-C on behalf of an Employer?
(4/29/15)
Reporting for Controlled Groups on Form 1094-C
(4/29/15)
Final Versions of 2014 ACA Employer/Plan Reporting Forms and Instructions
(3/1/15)
IRS Releases Draft Forms for Reporting of Employee Health Coverage under ACA
(7/31/14)
IRS Released Two Final Rules on Employer/Plan Reporting
(3/25/14)
IRS Released Two Proposed Rules on Employer/Plan Reporting
(10/24/13)
Official Source Documents
IRS Notice 2019-63
(12/2/19)
IRS Extends Due Date for 1095-C
(12/22/17)
2016 Form 1095-C
(1/23/17)
2016 Form 1094-C
(1/23/17)
2016 Instruction for Forms 1094/1095-C
(1/23/17)
IRS Notice 2016-70, Extension of Due Date
(11/21/16)
Federal Register: Proposed Rule on MEC Reporting, August 2, 2016
(8/23/16)
IRS ACA Reporting Corrections ppt
(6/29/16)
Extension of Due Dates for ACA ALE & MEC Information Reporting
(12/29/15)
IRS Notice 2015-87: Variety of ACA Related Provisions
(12/17/15)
Federal Register: Final Rules Information Reporting by ALEs
(12/3/14)
IRS Notice 2012-32
(6/11/12)
IRS Notice 2012-33
(6/11/12)
Webinar
Webinar: ACA Employer and Plan Reporting Webinar for TPAs and TPA Clients
(11/20/15)
Rescissions
Articles and Materials
Retroactively Cancel Coverage under PPACA
(3/9/11)
Retroactive Rescission
(12/21/10)
Rescissions: Reg Writers Provide Insights on PPACA Issues (Fall 2010)
(10/19/10)
Sample Speeches
Articles and Materials
Political Overview & New Developments in PPACA: What's Going to Happen??
(4/5/11)
Report on Key PPACA Reg Developments and Attitude
(4/5/11)
Is PPACA Rationing?
(2/14/11)
Sample Speech: What the Fate of PPACA and What's Ahead
(2/10/11)
SCOTUS
Articles and Materials
Supreme Court Decision Upheld; Medicaid Provisions Must Be Reworked
(6/29/12)
What's Next After SCOTUS
(6/28/12)
The Morning After SCOTUS: A Reality Check & Prep
(6/27/12)
Official Source Documents
Supreme Court Opinion - June 28, 2012
(6/28/12)
Self-Funded Reports
Articles and Materials
Self Insured Health Benefit Plans
(7/27/11)
Official Source Documents
Self Funded Report to Congress
(7/27/11)
Group Health Plans Report: Form 5500 Annual Reports
(7/27/11)
Self-Funding
Articles and Materials
Self-Funding: Myths vs. Facts
(9/2/14)
Administrative Fix for Policy Cancelations
(11/15/13)
Self-Funding: Self-Funding Will Flourish in ACA
(1/28/13)
Shared Responsibility
Articles and Materials
IRS Released Two Final Rules on Employer/Plan Reporting
(3/26/14)
Transition Relief for 2014
(7/10/13)
Multiemployer Plans Transition Relief
(5/29/13)
New Exchange Regulations Include Exemptions to Individual Shared Responsibility Provision
(2/4/13)
ACA Premium Tax Credit Affordability
(2/1/13)
Play or Pay in 2014 (Shared Responsibility for Employers Regarding Health Coverage)
(1/2/13)
Minimum Value of an Employer-Sponsored Health Plan
(5/29/12)
Health Care Reform: Employer Mandate and Federal Subsidies
(8/17/11)
Official Source Documents
IRS Publication: Making a Shared Responsibility Payment... What you Need to Know
(12/15/14)
IRS Publication: Health Care Law: What's New for Individuals & Families (Tax Year 2014)
(12/15/14)
IRS Final Regulations on Individual Shared Responsibility
(9/3/13)
IRS Proposed Regulation on Individual Shared Responsibility
(5/7/13)
Individual Responsibility Q and A (Link)
(1/31/13)
IRS Notice 2012-58 - Determining Full-Time Employees
(9/4/12)
IRS Notice 2012-59 - Guidance on 90 Day Waiting Period Limitation
(9/4/12)
Student Health Insurance
Articles and Materials
CMS Issues Final Rules on the Affordable Care Act Requirements for Student Health Policies
(7/17/12)
Student health Insurance Coverage Subject to Certain PPACA Provisions
(5/2/11)
Official Source Documents
Student Health Insurance Proposed Regulation (Federal Register, February 11, 2011)
(4/28/11)
Summary of Benefits & Coverage
Articles and Materials
The New 2017 Summary of Benefits and Coverage (SBC) Template
(4/28/16)
SBC Calculator is Developed - WEBINAR to Follow
(6/5/12)
SBC Corrections, FAQs & Calculation Guidance Have Been Issued
(5/29/12)
Summary of Benefits and Coverage and Uniform Glossary
(4/18/12)
Agencies Issue FAQs for the Summary of Benefits & Coverage
(3/20/12)
DOL Changes Compliance Date for the Summary of Benefits and Coverage
(11/28/11)
DOL Changes Compliance Date for the Summary of Benefits and Coverage
(11/21/11)
DOL Comment Letter on the Summary Benefit of Coverage
(10/26/11)
Uniform Summary of Benefits and Coverage
(7/12/11)
Official Source Documents
SBC Calculator Correction
(7/27/12)
Link to the SBC Coverage Example Calculator
(5/14/12)
FAQs Regarding the Implementation of Summary of Benefits & Coverage
(5/14/12)
Corrected Sumarry of Benefits & Coverage Template
(5/14/12)
Corrected Sample Summary of Benefits & Coverage
(5/14/12)
Final Rules Released on the Summary of Benefits & Coverage & Uniform Glossary (Revised 4/12/12)
(2/9/12)
Tax Credits for Premiums
Articles and Materials
Spouse Eligibility for Premium Tax Credits in the Exchange
(10/24/13)
ACA Premium Tax Credit Affordability
(2/1/13)
Health Care Reform: Employer Mandate and Federal Subsidies
(8/17/11)
Treasury Releases Guidance on Health Reform Tax Credits
(8/12/11)
Official Source Documents
Premium Tax Credit: Form 8962 + Instructions for Form 8962
(1/26/15)
IRS Weblink: Q&As on the Premium Tax Credit
(1/26/15)
IRS Final Regulations on Premium Tax Credits
(9/10/12)
Treasury Fact Sheet on Premium Tax Credits
(8/12/11)
Premium Tax Credits - Proposed Reg
(8/12/11)
Tax on Plans
Articles and Materials
Fees on Plans and Policies for the Patient-Centered Outcomes Research Trust Fund (May 2014)
(5/29/14)
Transitional Reinsurance Fee, Exchanges & SHOP
(2/27/14)
Text of HHS Notice of Benefit & Payment Parameters for 2015
(11/26/13)
Program Integrity Rule
(11/1/13)
Transitional Reinsurance Fee: Changes in New Regulations
(10/29/13)
PCORI Questions from SPBA Members
(6/27/13)
Insights on PCORI from Webinar (March 2013)
(5/13/13)
Reinsurance Fees Comment Letter
(1/4/13)
Reinsurance Fee and the Impact on TPAs and Self-Funded Plans
(12/17/12)
Official Source Documents
Dollar Amount 2015/2016 (IRS Notice 2015-60)
(2/24/16)
Transitional Reinsurance 2013-28610
(11/26/13)
Transitional Reinsurance Regulation 10-30-13 (Federal Register)
(10/31/13)
Final Rule
(10/28/13)
Reinsurance Fees: Payment Notice Technical Summary
(3/12/13)
Reinsurance Fees: Federal Register Proposed Regulations
(12/18/12)
PCORI: Federal Register Final Regulations
(12/10/12)
Transitional Reinsurance Program
Articles and Materials
Key Deadlines for Transitional Reinsurance Contributions
(12/13/16)
Release of ACA Transitional Reinsurance Program Annual Enrollment & Contributions Submission Form
(10/22/14)
Annual Enrollment & Contributions Submission Form Manual
(10/22/14)
Supporting Documentation Job Aid Manual
(10/22/14)
Official Source Documents
Proposed HHS Notice of Benefit & Payment Parameters for 2016 Fact Sheet
(12/2/14)
Transitional Reinsurance Program Proposed Regulations
(12/2/14)
Vouchers
Articles and Materials
Free Choice Vouchers
(11/23/11)
W-2s
Articles and Materials
ACA IRS W-2 Presentation
(3/6/12)
W-2 Reporting and Controlled Groups
(2/29/12)
Double Hot News: W-2 Health Value Reporting Chart + Hospital Transparency (e-mail alert)
(2/24/12)
Article on IRS W-2 Guidance in 2012
(2/3/12)
W-2 Health Care Value Reporting Updated
(1/27/12)
W-2 Health Care Cost Reporting Interim Guidance (Article)
(5/3/11)
History on W-2 Health Value Reporting
(10/25/10)
W-2 Health Care Cost Reporting Optional for 2011
(10/19/10)
No Tax on Benefits $ on W-2
(8/20/10)
W-2 Health Care Cost Reporting
(8/20/10)
W-2 Reporting on the Value of Health Coverage
(6/10/10)
Official Source Documents
W-2 Health Value Reporting IRS Chart Link
(12/24/14)
W-2 Health Value Reporting IRS FAQs Link
(11/24/14)
IRS W-2 Guidance in 2012
(2/3/12)
Wellness
Articles and Materials
SPBA Comments to EEOC on Proposed Wellness Rule
(6/19/15)
EEOC Wellness Proposed Rule Article
(4/28/15)
Official Source Documents
DOL-IRS-HHS Wellness FAQ - April 2015
(4/28/15)
HHS FAQs on Wellness April 2015
(4/28/15)
HIPAA Nondiscriminatory Wellness Programs: Final Regulation
(5/30/13)
Webinar
Webinar: An Overview of Wellness Rules Governing Health Plans
(10/2/23)