Letters to Agencies – ACA

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ERIC Sends IRS Letter on ACA Penalties

We are writing to raise concerns with the process created by the Internal Revenue Service to assess Employer Shared Responsibility Payment penalties under the Affordable Care Act relating to determinations that an employer may have failed to offer affordable, minimum essential coverage to its full-time employees… More

protected content Coalition Letter Submitted to on Massachusetts EMAC; Win in the House

As we’ve alerted you to previously, the Massachusetts Employer Medical Assistance Contribution is scheduled to sunset at the end of this year, but there is some concern that it may be extended… More

protected content Alert: ERIC Signs Letter on Massachusetts Employer Medical Assistance Contribution Supplement Tax

want to provide a brief update on the Massachusetts Employer Medical Assistance Contribution supplement tax (EMAC)… More

ERIC Responds to RFI on Grandfathered Health Plans

The ERISA Industry Committee is pleased to submit these comments in response to a recently-issued request for information (RFI) on grandfathered health plans… More

ERIC Submits Comments on North Dakota’s Reinsurance Program

On behalf of The ERISA Industry Committee (ERIC), thank you for accepting input from interested stakeholders as you explore ways to stabilize North Dakota’s individual health insurance market through a reinsurance program… More

ERIC Submits Comments on Proposal to Expand Health Reimbursement Arrangements

ERIC submitted comments on the Trump Administration’s proposal to expand and facilitate access to Health Reimbursement Arrangements (HRAs) and other account-based plans… More

ERIC Submits Comments to CMS on 1332 Waivers

The ERISA Industry Committee is pleased to submit these comments in response to the Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services (HHS), and the Department of the Treasury (Treasury) guidance related to section 1332 of the Patient Protection and Affordable Care Act (ACA) and its implementing regulations, published in the Federal Register on October 24, 2018… More

ERIC Submits Comments to HHS on the President’s “American Patients First” Blueprint

Today, ERIC submitted comments to the Department of Health and Human Services (HHS) in response to its Request for Information related to the HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs… More

Employer Groups Call for Suspension of Tax Assessments and Repeal of the Employer Mandate

The ERISA Industry Committee (ERIC) joined a number of employer trade associations to call upon the U.S. Department of the Treasury, the Department of Health and Human Services, and the Internal Revenue Service to end the illegal enforcement of the Affordable Care Act’s employer mandate… More

ERIC Comments to HHS on ACA Regulatory Reforms

The ERISA Industry Committee (“ERIC”) is pleased to comment on the request for information by the Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) on June 8, 2017, concerning regulatory actions within HHS jurisdiction that could be taken to reduce the burdens of the ACA… More

ERIC Urges Departments to Maintain Flexibility for Expat Plans and Supplemental Benefits

ERIC submitted comments to the Department of Labor, Department of Health and Human Services, and the Internal Revenue Service on proposed rules governing health plans for expatriates, as well certain supplemental health benefit plans… More

ERIC Asks Treasury Department for 60 Day Delay in Furnishing Deadline

The ERISA Industry Committee (ERIC) today submitted comments to the U.S. Treasury Department requesting at least a 60-day delay in the furnishing deadline… More

ERIC Makes Recommendations on the 40 Percent Excise Tax

The ERISA Industry Committee (ERIC) submitted comments and recommendations to the Internal Revenue Service (IRS) on potential rules regarding the Affordable Care Act’s 40 percent excise tax on employer-sponsored health coverage… More

ERIC Files Comments on Proposed EEOC Wellness Regulations

The ERISA Industry Committee (“ERIC”) is pleased to submit this response to the request for comments on proposed rulemaking regarding Title I of the Americans with Disabilities Act (“ADA”) as it relates to employer wellness programs.  The request was published by the Equal Employment Opportunity Commission (the “Commission”) in the Federal Register on April 20, 2015.… More

ERIC Files Comment Letter on Draft Forms and Instructions for ACA Reporting

The ERISA Industry Committee (ERIC) recently filed comments with the Treasury Department and Internal Revenue Service on the draft forms and instructions for the Affordable Care Act (ACA) reporting requirements applicable to health plan coverage offered under employer-sponsored plans. … More

protected content ERIC Files Comment Letter on Cost-Sharing Guidance

ERIC recently filed a comment letter with the Department of Labor, Department of Health & Human Services and the Treasury Department on the FAQs About Affordable Care Act Implementation (Part XIX) issued in May 2014. … More

ERIC Offers Recommendations on Proposed Changes to Excepted Benefits Definition

The ERISA Industry Committee (ERIC) on March 7 offered a series of recommendations to make sure that plan sponsors may continue to make their employee assistance programs available to all of their employees. … More

ERIC Asks that Transitional Reinsurance Fee Be Implemented on Fair and Impartial Basis

The ERISA Industry Committee (ERIC) today submitted comments to the Department of Health and Human Services (HHS) urging the agency to ensure that the method for computing the transitional reinsurance fee under the Affordable Care Act (ACA) not impose unnecessary administrative burdens or costs on employers, and that the fee be applied on a fair and impartial basis. … More

ERIC Recommends that IRS Further Simplify ACA Employer Information-Reporting Requirements before Treasury/IRS Hearing

Richard Stover, Principal and Consulting Actuary of Buck Consultants (a Xerox Company), testified today on behalf of The ERISA Industry Committee (ERIC) before a joint Treasury Department and IRS hearing on proposed regulations under the Affordable Care Act on information reporting by large employers on health coverage. … More

ERIC Urges IRS to Further Simplify ACA Employer Information-Reporting Requirements

The ERISA Industry Committee (ERIC) today filed comments urging the IRS to further revise and simplify the proposed regulations concerning reporting requirements applicable to health insurance coverage offered under employer-sponsored plans. … More

ERIC Suggests Revisions to ACA Minimum Value Proposed Regulations

The ERISA Industry Committee (ERIC) today submitted to the Internal Revenue Service a series of recommendations to improve proposed regulations relating to the determination of affordability and minimum value of eligible employer-sponsored plans under the Affordable Care Act (ACA).… More

ERIC Urges CMS to Reconsider Restrictive Requirements on Part D Automatic Prescription Refills

ERIC, along with several other employer business groups, on June 11 wrote to the Centers for Medicare and Medicaid Services urging the agency to reconsider unnecessarily restrictive requirements on automatic prescription refill programs under Medicare Part D. … More

ERIC Urges Greater Flexibility and Clarity for ACA Out-of-Pocket Rules

The ERISA Industry Committee (ERIC) has written to the Departments of Health and Human Services, Labor, and Treasury urging the agencies to provide greater flexibility and clarity with respect to the out-of-pockets rules under the Affordable Care Act (ACA). … More

ERIC Recommends Revisions to Shared Responsibility Proposed Regulations

The ERISA Industry Committee (ERIC) filed comments today urging the Treasury Department and Internal Revenue Service (the Agencies) to revise the shared responsibility proposed regulations to better accommodate the implementation challenges and administrative complexities faced by large, multinational companies with diverse workforces.… More

ERIC Cautions Regulators to Avoid Burdensome Claims and Appeals Requirements

Washington, D.C. -- The ERISA Industry Committee (ERIC) today submitted comments on the amendment to the interim final regulations… More

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