EBIA Weekly Newsletter

IRS Updates Procedures for Letter Rulings, Determination Letters, and Other Guidance, and Consolidates Employee Plans Procedures


   January 12, 2017

Rev. Procs. 2017-1 and 2017-4, 2017-1 I.R.B. 1 (Jan. 3, 2017) Available at https://www.irs.gov/pub/irs-irbs/irb17-01.pdf The IRS has updated and restated its revenue procedures governing letter rulings, determination letters, and other guidance, including guidance about employee benefit plans. These revenue procedures supersede, and in some instances consolidate, their 2016 counterparts. Here are highlights for … Read More


Must ALEs File Form 1095-C for Foreign Employees?


   January 12, 2017

QUESTION: We are an applicable large employer (ALE) with foreign employees (non-U.S. citizens) who are working 40 hours per week legally in the U.S. Do we have to prepare Form 1095-C for these employees? ANSWER: Yes, all employees credited with enough hours of service to be considered full-time employees for purposes of calculating employer shared … Read More


HHS Releases Final Notice of Benefit and Payment Parameters for 2018


   January 5, 2017

PPACA; HHS Notice of Benefit and Payment Parameters for 2018; Amendments to Special Enrollment Periods and the Consumer Operated and Oriented Plan Program, 45 CFR Parts 144, 146, 147, 148, 153, 154, 155, 156, 157, and 158, 81 Fed. Reg. 94058 (Dec. 22, 2016); Final HHS Notice of Benefit and Payment Parameters for 2018 Fact … Read More


DOL Report: EBSA Lacks Resources to Properly Protect Self-Insured Health Plan Participants


   January 5, 2017

DOL Office of Inspector General: Report to the Employee Benefits Security Administration (Nov. 18, 2016) Available at http://www.oig.dol.gov/public/reports/oa/2017/05-17-001-12-121.pdf The Department of Labor’s Office of the Inspector General has issued a report concluding that the Employee Benefit Security Administration (EBSA) has been unable to protect an estimated 79 million self-insured health plan participants from … Read More