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June 28, 2016
Health Care Reform

Agencies Publish FAQs on ACA Implementation, Part XXXII

On June 21, 2016, the DOL, HHS and IRS jointly published an FAQ, FAQs about Affordable Care Act Implementation (Part 32), addressing whether a COBRA election notice can include additional information about health insurance marketplace (also known as “public exchange”) coverage options. As a reminder, the COBRA model election notice contains information about enrollment in the marketplaces which may yield a more cost-effective option for coverage.
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IRS Health Care Tax Tip 2016-57: Deadline Reminder for Employers and Providers: Electronically File Information Returns with IRS by June 30

On June 22, 2016, the IRS released IRS Health Care Tax Tip 2016-57, which provides an important reminder of the fast approaching June 30 deadline for employers and providers to electronically file information returns (IRS Forms 1094-C and 1095-C) with the IRS.
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Federal Updates

EEOC Issues Sample Notice for Wellness Programs

On May 17, 2016, the EEOC published final regulations related to employer sponsored wellness programs (see May 17, 2016, edition of Compliance Corner). Those regulations require wellness programs which include a disability related inquiry or medical examination to provide a notice to employees. That notice must explain what medical information will be obtained, who will receive the medical information, how the medical information will be used, the restrictions on its disclosure and the methods the covered entity will employ to prevent improper disclosure of the medical information. On June 16, 2016, the EEOC released a sample notice that employers may use to meet this requirement.
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