Compliance March 2, 2015

IRS Issues Guidance About ACA Cadillac Tax

Under the ACA, if the aggregate cost of “applicable employer-sponsored coverage” provided to an employee exceeds a statutory dollar limit, the excess is subject to a 40% excise tax.
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The Internal Revenue Service (IRS) has issued Notice 2015-16 to initiate the process of developing regulatory guidance regarding the excise tax on high-cost employer-sponsored health coverage. The so-called Cadillac tax was added to the Internal Revenue Code by the Patient Protection and Affordable Care Act (ACA).

Beginning in 2018, if the aggregate cost of “applicable employer-sponsored coverage” provided to an employee exceeds a statutory dollar limit, which will be revised annually, the excess is subject to a 40% excise tax. The notice describes potential approaches with regard to a number of issues that could be incorporated in future proposed regulations, and invites comments on these potential methods. The issues addressed primarily relate to (1) the definition of applicable coverage, (2) the determination of the cost of applicable coverage, and (3) the application of the annual statutory dollar limit to the cost of applicable coverage.

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The IRS says it anticipates issuing another notice before the publication of proposed regulations, describing and inviting comments about procedural issues relating to the calculation and assessment of the excise tax. After considering the comments on both notices, the IRS anticipates publishing proposed regulations.

Public comments should be submitted no later than May 15, 2015.

In addition, the IRS issued Notice 2015-17, which reiterates the conclusion in previous guidance addressing certain health coverage reimbursement arrangements, including Notice 2013-54, that these arrangements are group health plans that will fail to comply with the market reforms that apply to these plans under the ACA. The notice also provides transition relief from the assessment of excise tax for failure to satisfy market reforms in certain circumstances.

Reader Responses March 2, 2015

SURVEY SAYS: Asleep on the Job

Recently, we covered a survey that found 38% of Americans say they have fallen asleep at work.
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Last week, I asked NewsDash readers, have you fallen asleep on the job? What other work mistakes have you made because you were tired? And, how do you refresh yourself when tired at work?

More than 64% of respondents are plan sponsors, 16.7% are advisers/consultants and 19% work in a TPA/recordkeeper/investment manager role.

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Nearly six in ten respondents (58.5%) admitted they have fallen asleep at their desk, in their car or in another work area due to being tired at work, and 29.3% said they have fallen asleep in a meeting, during a presentation or on a phone call. Fifty-six percent of responding readers reported being tired at work caused them to make typos in a written communication.

Nearly 10% had a wardrobe malfunction due to being tired at work, 14.6% sent an email to the wrong person or group of persons, and 24.4% called a coworker or client the wrong name. Being tired caused 14.6% of responding readers to miss a meeting, presentation or phone call and caused 2.4% to put an investment order in for the wrong amount. Nearly 15% said they forgot a needed item for work or a presentation, 4.9% went into the wrong bathroom, and 7.3% went into the wrong office or meeting room when they were tired.

“Other” responses, selected by 14.6% of respondents, included losing concentration, forgetting the office was closed for the holiday, and falling asleep on the train on the way home and missing a stop. One reader indicated he/she had done most of actions at some point, but it wasn’t necessarily due to being tired at work. Another indicated he/she didn’t actually fall asleep because of a head jerk.

Asked how they refresh themselves when tired at work, 53.7% of responding readers selected “coffee” and 4.9% selected “energy drink.” Thirty-four percent said they snack, 78% said they stretch, take a walk, or exercise, and 22% have a non-work-related conversation with a coworker. Nearly %% reported they listen to music to refresh themselves.

“Other” responses, selected by 31.7% of respondents, included drinking tea, soda or water, taking a catnap during lunch, reading a non-work-related book, and “walk through manufacturing.”

Many of those who chose to make general comments noted that big lunches, warm rooms and boring people lead to sleepiness at work. One suggested an office sofa just for catnaps. One reader said, “This was such a huge problem for me it had a somewhat significant influence on the timing of my retirement,” while another said it was such a worrisome problem he/she went to the doctor and was diagnosed with sleep apnea. Editor’s Choice goes to the reader who said: “Mostly I am just tired of being at work! Some days, I think a walk…all the way home…would be the right idea!”

Thanks to everyone who responded to the survey!

 

Verbatim

Avoid big lunches and carb loading, you will crash!

Mostly I am just tired of being at work! Some days, I think a walk...all the way home...would be the right idea!

This was such a huge problem for me it had a somewhat significant influence on the timing of my retirement.

Warm conference rooms with boring portfolio managers will do it every time.

Have almost dozed off during an interview. It was right after lunch, the room was warm and we were hiring for an engineering position--pretty boring stuff.

It usually happens right after lunch, between 1:00 and 2:00 pm.

My office needs a sleep sofa for catnaps.

I haven't fallen truly asleep in a meeting, but have felt that "vertigo" sensation while borderline awake.

If we had enough staff so we could work a normal length day and have time to take care of family duties prior to bedtime, we might get enough sleep at night to avoid being sleepy at work - just a thought.

I would get more sleep if I could, but it eludes me.

ZZZZZZZZZZZZZZZZZ Oh, so sorry, I nodded off. Ahem, my tiredness at work was due to either blinding migraines -- OR -- extreme boredom during a meeting or presentation. ZZZZZZZZZZZZZZZZ

Although I have been tired as a result of all-nighters or jet-lag traveling to Asia, I have never fallen asleep while at work.

I wish I was as tired at night when I am trying to sleep as I am when I am at work! Or maybe I am just tired at work because I can't sleep at night. [ Yawn 🙂 ]

The type of folks responding here don't know physically tired from work. It's all in their exhausting heads.

I was concerned about the tiredness and went to the doctor only to find out I had sleep apnea.

 

NOTE: Responses reflect the opinions of individual readers and not necessarily the stance of Asset International or its affiliates.

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