Loss of Health Plan Eligibility Caused by Move to Part-Time Work

Question:  When does an employee lose health plan eligibility upon a change in employment status to part-time work? Compliance Team Response: Reminder: Very Different Approach Depending on Measurement Method There are two different approaches for an applicable large employer (ALE) subject to the ACA employer mandate pay or play rules to determine employees’ full-time status: […]

Employer Commuter Benefit Subsidies

Question:  What compliance issues should employers be aware of if they want to add a commuter benefit subsidy? Compliance Team Response: General Tax-Advantaged Status of Qualified Transportation Plans Under IRC §132(f) IRC §132(f) provides a tax-advantaged limit of $265 per month that may be contributed to a transit pass/vanpooling and/or parking commuter benefit program.  This […]

SF HCSO City Option Contributions

Question:  What are the basic rules that apply for SF HCSO City Option Contributions that are used to fund a SF MRA for employees? Compliance Team Response: City Option Contributions Employers subject to the SF HCSO must make quarterly contributions to the City Option for covered employees if the employer is not satisfying the required […]

How the ACA Applies to Contingent Workers

Question:  What are the ACA rules surrounding offering benefits to the contingent workforce, and how do most employers approach the issue? Compliance Team Response:   The “contingent workforce” category generally breaks down into three practical groups that each require a separate analysis: Employees on the Employer’s Payroll Employees Hired Through an Outside Staffing Firm Properly […]

California and New Jersey HSA State Income Tax

Question:  Which states tax HSAs at the state income tax level, and how does that affect employers? Compliance Team Response: General Rule: HSAs are Triple-Tax Advantaged HSAs offer an unparalleled three tiers of federal tax savings: Pre-Tax Contributions Employee contributions through payroll are made on a pre-tax basis through the Section 125 cafeteria plan Employee […]

How ACA Affects Flex Credits

Question:  What are some of the main compliance considerations for employers that are implementing a flex credit contribution approach? Compliance Team Response: Flex credits are a feature available under a Section 125 cafeteria plan for employers to provide a defined contribution amount that employees may allocate among various qualified benefits. Employers enjoy a considerable amount […]

ACA Employer Mandate and Outside Staffing Firms

Question:  How does the ACA employer mandate apply to workers hired through an outside staffing firm? Compliance Team Response: ACA Employer Mandate: Applies to Common-Law Employees The ACA employer mandate rules apply only to an employer’s common-law employees. ACA Employer Mandate: Workers Payrolled Through an Outside Staffing Firm Full-time workers hired through an outside staffing […]

Common Summer Intern Approaches Under the ACA

Question:  What are some common options for employers in deciding how and when to offer health plan coverage to summer interns? Compliance Team Response: ACA Employer Mandate General Rule: New Full-Time Hires The ACA employer mandate pay or play rules permit a standard limited non-assessment period for new full-time hires. That limited non-assessment period generally […]

IRS Releases 2020 Inflation Adjusted Amounts for HSAs

The IRS has released Revenue Procedure 2019-25 detailing the HSA contribution limit increases for 2020. The 2020 HSA contribution limit for individual coverage will increase by $50 to $3,550. The 2020 HSA contribution limit for family coverage (employee plus at least one dependent) will increase by $100 to $7,100. The catch-up contribution limit of $1,000 […]