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April 25, 2012
by Gary M. Ford
The Internal Revenue Service, Department of Labor, and Department of
Health and Human Services have issued a series guidance that summarizes their intended
direction in implementing the employer shared responsibility
requirement and related Patient Protection and Affordable Care Act requirements. Most recently, IRS
Notice 2012-17 and DOL Technical Release 2012-01 address the PPACA
employer shared responsibility requirement, automatic enrollment
requirement, and waiting period limitation in a series of
"frequently asked" questions and answers.
A Possible Alternative to the Moench-ies (Part II)
Attorneys Make Predictions on Fee Litigation, Questions of Constitutional Standing
Battle Over Presumption of Prudence Heats Up Ahead of High Court Arguments
IRS Windsor Retroactivity Guidance Leaves Questions on ERISA Claims, Practitioners Say
Retirement Plans Aren't Required to Apply Windsor Ruling Retroactively, IRS Says