Furnishing Deadline Delayed for 2018 ACA Reporting

Furnishing Deadline Delayed for 2018 ACA Reporting

On Nov. 29, 2018, the Internal Revenue Service (IRS) issued Notice 2018-94 to:

  • Extend the due date for furnishing forms under Sections 6055 and 6056 for 2018 from Jan. 31, 2019, to March 4, 2019; and
  • Extend good-faith transition relief from penalties related to 2018 information reporting under Sections 6055 and 6056.

Notice 2018-94 does not extend the due date for filing forms with the IRS for 2018. The due date for filing with the IRS under Sections 6055 and 6056 remains Feb. 28, 2019 (April 1, 2019, if filing electronically, since March 31, 2019, is a Sunday). (more…)

Proposed Rule Would Expand Options for HRAs

Proposed Rule Would Expand Options for HRAs

On Oct. 23, 2018, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) issued a proposed rule that would expand the usability of health reimbursement arrangements (HRAs). Effective in 2020, the proposed rule would:

  • Allow HRAs to be used to reimburse the cost of individual market premiums on a tax-preferred basis, subject to certain conditions; and
  • Allow employers that offer traditional group coverage to provide an HRA of up to $1,800 per year (as adjusted) to reimburse certain qualified medical expenses.

This proposed rule was issued in response to a 2017 executive order directing federal agencies to expand access to HRAs. (more…)

Final Forms for 2018 ACA Reporting Released

Final Forms for 2018 ACA Reporting Released

In late Sept. 2018, the Internal Revenue Service (IRS) released final 2018 forms and instructions for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

  • 2018 Forms 1094-C and 1095-C (and related instructions) are used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
  • 2018 Forms 1094-B and 1095-B (and related instructions) are used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

The 2018 forms and instructions are substantially similar to the 2017 versions. (more…)

IRS Issues Guidance on Tax Credit for Paid Family and Medical Leave

IRS Issues Guidance on Tax Credit for Paid Family and Medical Leave

The IRS recently released Notice 2018-71, which provides detailed guidance in question and answer (Q&A) format on the employer tax credit for paid family and medical leave. The tax credit is contained in Section 45S of the Internal Revenue Code (Code) and applies for 2018 and 2019 tax years.

The IRS’ Q&As address the following topics:

  • Eligible employers;
  • Family and medical leave;
  • Minimum paid leave requirements; and
  • Calculating and claiming the credit.

This IRS guidance applies to taxable years beginning after Dec. 31, 2017, and before Jan. 1, 2020. The IRS also intends to issue proposed regulations on the tax credit in the future. (more…)

Don’t Forget About PCORI Fees

Don’t Forget About PCORI Fees

The ACA imposes a fee on health insurance issuers and plan sponsors of self-insured health plans to help fund the Patient-Centered Outcomes Research Institute. The fee, called the Patient-Centered Outcomes Research Institute (PCORI) fee, is calculated based on the average number of lives covered under the policy or plan. (more…)

IRS Announces HSA Limits for 2019

IRS Announces HSA Limits for 2019

On May 10, 2018, the IRS released Revenue Procedure 2018-30 to announce the inflation-adjusted limits for health savings accounts (HSAs) and high deductible health plans (HDHPs) for 2019. These limits include:

  • The maximum HSA contribution limit;
  • The minimum deductible amount for HDHPs; and
  • The maximum out-of-pocket expense limit for HDHPs.

These limits vary based on whether an individual has self-only or family coverage under an HDHP.

The IRS limits for HSA contributions will increase for 2019. The HDHP maximum out-of-pocket limits will also increase for 2019. The HSA contribution limits will increase effective Jan. 1, 2019, while the HDHP limits will increase effective for plan years beginning on or after Jan. 1, 2019. (more…)