Vigilant Blog

H.R. 1473, P.L.  112-10). This provision was set to take effect on January 1, 2014 and was intended to make exchange coverage affordable for employees with low incomes who were not eligible for federal income-based assistance.  It remains to be seen how this development will affect employers’ strategies for addressing health reforms in 2014. Vigilant…

If the courts take the same approach as the EEOC did in this case, it will be a huge relief for employers. One question that was left unanswered, though, is what happens when there is a significant gap in time between an employee’s last date of employment, and the date of retirement. Does the statute…

HR 2, titled “Repealing the Job-Killing Health Care Law Act” and many other proposed bills. But regardless of the volume of legislative activity devoted to opposing health care reform, most experts agree that if our legislators have anything to say about it, health care reform is here to stay. The Democratic-controlled Senate is unlikely to…

IRS Notice 2011-5).The new guidance modifies previous IRS guidance and allows FSA and HRA debit cards to be used to purchase OTC medicines or drugs at non-health care merchants that have pharmacies, and at mail order and web-based vendors that sell prescription drugs, as long as certain conditions are met. Debit cards may also be…

The U.S. Department of Labor (DOL) recently promised to issue guidance about automatic enrollment in employer-sponsored health plans—sometime in the next three years. Automatic enrollment is a mandate imposed by last year’s health care reform law, the Patient Protection and Affordable Care Act (PPACA). The mandate will apply to employers of 200 or more employees…

If you sponsor an insured, non-grandfathered group health plan, Christmas has come a little early this year. The IRS has officially delayed the effective date of the impending nondiscrimination requirements for insured plans until after regulations or other administrative guidance can be issued (

Kristine Cienfuegos at 800-733-8621.

fourth set of FAQs clarifies that this notice need not be included on the explanation of benefits (EOB) documents issued by the plan in response to a claim for benefits, but that it should be included in any plan summaries, such as the summary plan description (SPD) or similar documents. No further guidance is available…

Regulators at the Departments of the Treasury (IRS), Labor (DOL) and Health and Human Services (HHS) recently issued an amendment to earlier guidance on grandfathered health plans, permitting plans to change insurers without losing grandfathered status (Health Care Reform Blog, or contact

issued a notice stating that such reporting would be voluntary for the 2011 tax year. Employers should expect that the reporting requirement will be mandatory for the 2012 tax year, but Vigilant will update you as developments occur.

The U.S. Department of Labor (DOL) says it will focus on helping employers and health plans understand and apply the new health care reform law. Recently the DOL posted new guidance on its website. Some of the highlights are: interim regulations state that more than a five percent decrease in the employer’s contribution rate will…