| Society of Professional Benefit Administrators

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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)

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)