Before slipping away for the year-end recess, Congress enacted new laws, and the IRS issued new guidance, pertaining to a myriad of Affordable Care Act (“ACA”) matters. As a welcomed change, most of the actions are favorable to employers. In this alert, Schwabe attorney Walter Miller describes the recent ACA developments in detail, including:
- Postponement of the Cadillac Tax
- Extension of ACA Form 1094-C reporting deadlines
- New IRS guidance on calculation of hours of service for ACA full-time employee status
- Clarification of restrictions on HRAs
- Effect of opt-out payments on ACA affordability determination
- Relaxation of health FSA carryover restrictions
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