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QUICK FACTS: A Circuit Court has ruled that the ACA’s individual shared responsibility mandate is unconstitutional, in agreement with an earlier District Court ruling. But the Circuit Court sent the case back to the District Court to reconsider whether the unconstitutionality of the individual mandate means that the entire ACA is unconstitutional. The case is likely to remain in litigation for the foreseeable future, as court decisions will likely continue to be appealed. In the meantime, all ACA employer obligations, such as the employer shared responsibility mandate and ACA reporting remain intact, as do all existing market reform rules …

The Internal Revenue Service (IRS) has released Notice 2019-63 (Notice) which extends the due date for furnishing to individuals the 2019 Form 1095-B (generally provided by insurers), and the 2019 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from January 31, 2020, to March 2, 2020. The Notice also extends good faith transition relief from penalties relating to 2019 Affordable Care Act (ACA) information reporting requirements under Internal Revenue Code (IRC) sections 6055 and 6056.  Finally, the Notice provides new relief relating to the failure to furnish information required by IRC section 6055 under certain circumstances …

… or did not offer or provide to their employees during the prior calendar year. Each reporting entity must file annually: A separate statement (Form 1095-B or 1095-C) for each individual who was provided with minimum essential coverage (for providers reporting under Section 6055), or for each full-time employee (for ALEs reporting under Section 6056), respectively; and A transmittal form (Form 1094-B or 1094-C) for all of the returns filed for a given calendar year with the IRS. DUE DATES Reporting entities must furnish individual statements (Form 1095-B, 1095-C, or a substitute form) to …

… 500$19,000 Maximum “Catch-Up” Salary Deferral (age 50 or older)$6,500$6,000 Compensation Limit (401(a))$285,000$280,000 Maximum Defined Benefit Limit$230,000$225,000 Defined Contribution Annual Additions Limit (415)$57,000$56,000 Defined Contribution Annual Additions Limit (415) If age 50 or older$63,500$62,000 “Key Employee” Compensation Limit$185,000$180,000 “Highly Compensated Employee” Limit$130,000$125,000 EPIC Employee Benefits Compliance Services For further information on this or any other topics, please contact your EPIC consulting team. Learn About Our Employee Benefits Compliance Services EPIC offers this material for general information only. EPIC does not intend …

QUICK FACTS The Health Insurance Portability and Accountability Act (HIPAA) contains stringent privacy and security rules that group health plans, as covered entities, must follow to safeguard participants’ protected health information (PHI). The Department of Health and Human Services (HHS), through the Office of Civil Rights (OCR), enforces the privacy and security rules and can assess fines against non-compliant covered entity group health plans. The OCR continues to address HIPAA complaints and monitor covered entities to ensure that they meet their HIPAA obligations. Plan sponsors should ensure that the devices used to manage or store sensitive PHI are properly …