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Compliance Corner

April 4, 2017

Health Care Reform

House Republicans Cancel Vote on the American Health Care Act

On March 24, 2017, the U.S. House of Representatives canceled a vote on the proposed ACA replacement plan, known as the American Health Care Act (AHCA). According to House leadership, the Republicans could not garner enough support for the AHCA to pass the House. Following the cancelation, House Speaker Paul Ryan (R-WI) and Pres. Trump stated that the ACA repeal and replace efforts will be put on the backburner and that Congress would move on to other Congressional agenda items, including tax reform. However, since those announcements, there have been ongoing discussions behind the scenes regarding a revival of the ACA repeal and replace efforts. So Congress may revisit the issue in the near future.

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IRS Provides Guidance Related to Premium Tax Credit Eligibility

On March 16, 2017, the IRS updated its online resource “Questions and Answers on the Premium Tax Credit.” The revised Question #15 specifically addresses the eligibility of a spouse and dependent for a premium tax credit. Generally, a spouse and dependent are not eligible for a premium tax credit if they are eligible to enroll in the employee’s group health plan and the coverage provided to the employee is of minimum value and affordable.

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Retirement Updates

IRS Announces Non-Applicability of Conflict of Interest Rule Excise Taxes

On March 28, 2017, the IRS released Announcement 2017-4, announcing that they are adopting a temporary non-applicability policy on any excise taxes that could be levied as a result of the DOL’s Conflict of Interest Rule (the Rule). As we reported in the last edition of Compliance Corner, the DOL recently released Field Assistance Bulletin (FAB) No. 2017-01. The FAB announced a temporary enforcement policy related to the DOL’s Rule, which broadens the definition of the term “fiduciary” under ERISA.

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Announcements

Compliance Podcast Episode 5

This week Suzanne Spradley and Chase Cannon discuss the House’s decision to cancel a vote on the American Health Care Act, and what that means for future Republican efforts to repeal and replace the ACA.

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Reminder: 2016 HSA Contributions and Corrections Deadline is April 18

Individuals who were HSA eligible in 2016 have until the tax filing deadline to make or receive contributions. Thus, 2016 HSA contributions must generally be made by April 18, 2017. This includes employer contributions. The 2016 contribution limit is $3,350 for self-only coverage and $6,750 for any tier of coverage other than self-only. Those aged 55 and older are permitted an additional catch-up contribution of $1,000.

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DOL and IRS Hosting Educational Seminars

On April 19-20, 2017, the DOL will host a Health Benefits Laws Compliance Assistance Seminar in Salt Lake City, UT. This seminar is a joint venture by the DOL and the Utah Insurance Department, where they will provide practical information, helpful tips, and clarification on Utah and federal health benefits laws.

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State Updates

California

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Colorado

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Idaho

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South Dakota

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Utah

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Virginia

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FAQ

An employer-sponsored group health plan has a wellness program with rewards for completing wellness requirements. Are terminated employees who have elected COBRA eligible to participate in the wellness program?

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Reference

Commonly Used Acronyms

Glossary »
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NFP Corp. and its subsidiaries do not provide legal or tax advice. Compliance, regulatory and related content is for general informational purposes and is not guaranteed to be accurate or complete. You should consult an attorney or tax professional regarding the application or potential implications of laws, regulations or policies to your specific circumstances.