By Edward I. Leeds, Esq.
Ballard Spahr LLP, Philadelphia, PA
In the Consolidated and Further Continuing Appropriations Act (the recently enacted federal budget bill often known as the "CRomnibus" legislation), Congress has exempted health plans designed to cover expatriates from most of the requirements of the Affordable Care Act. The exemption will generally apply where a group health plan provides significant health coverage and substantially all of the covered employees fall under any of the following categories:
Although the exemption is extensive, expatriate plans must continue to meet certain ACA requirements. For example:
By its terms, the new exemption applies only to health plans issued or renewed on or after July 1, 2015. However, for many expatriate plans, there are currently exemptions in place for market reforms and certain fees and assessments required under the ACA. We would be glad to help you evaluate whether any of the current or future exemptions apply to the health coverage provided to your expatriate employees.
As the federal health care reform effort gained steam, Ballard Spahr attorneys established the Health Care Reform Initiative] to monitor and analyze legislative developments. With federal health care reform now a reality, our attorneys are assisting health care entities and employers in understanding the relevant changes and planning for the future. They also have launched the Health Care Reform Dashboard, an online resource center for news and analysis on developments under the Affordable Care Act.
If you have questions about this alert or other ACA-related considerations, please contact Edward I. Leeds at 215.864.8419 or firstname.lastname@example.org, Brian M. Pinheiro at 215.864.8511 or email@example.com, Jean C. Hemphill at 215.864.8539 or firstname.lastname@example.org, Diane A. Thompson at 424.204.4334 or email@example.com, or any other member of the Employee Benefits and Executive Compensation or Health Care Groups with whom you work.
For more information, in the Tax Management Portfolios, see Cowart, 389 T.M., Medical Plans — COBRA, HIPAA, HRAs, HSAs and Disability, and in Tax Practice Series, see ¶5920, Health & Disability Plans.
Copyright © 2015 by Ballard Spahr LLP.
(No claim to original U.S. government material.)
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