The Employer Shared Responsibility Provisions (commonly known as the “employer mandate”) under the Affordable Care Act (ACA) require covered large employers to pay an assessment under the Internal Revenue Code if they fail to offer health coverage to their full-time employees that meets certain standards. Those standards include a requirement that the coverage be affordable for full-time employees.… Continue Reading

The whirl of changes in employee benefits rules that have resulted from the pandemic include the temporary opportunity for employees to carry over unused amounts contributed to a dependent care flexible spending account from one year to another. The IRS has issued a new notice on these rules that clarifies how these rules apply in view of the increase in the maximum limit on dependent care assistance for 2021 to $10,500.… Continue Reading

On May 18, the IRS released Notice 2021-31. The notice contains detailed guidance on subsidies employers must provide COBRA beneficiaries pursuant to the American Rescue Plan Act (“ARP”), and uses a Q&A format to illustrate several specific examples and potential issues regarding the subsidies. For employers, one of the many issues of interest addressed in this notice is the determination of which employee departures qualify as involuntary terminations triggering COBRA assistance.… Continue Reading