Second Opinions

November 06, 2013

SECOND OPINIONS: ACA Checklist: 2014 Plan Amendments

November 6, 2013 ( - For the past few years, we have put together an annual list of ACA plan amendments that are required for the upcoming plan year.  Back by popular demand, below is our ACA checklist for 2014.

October 02, 2013

SECOND OPINIONS: ACA Application to HRAs and Other Arrangements

October 2, 2013 ( - On September 13, 2013, Treasury issued Notice 2013-54 (the “Notice”) (and the Department of Labor issued substantially identical guidance in Technical Release 2013-03) on the application of certain Affordable Care Act (ACA) provisions to health reimbursement arrangements (“HRAs”), health flexible spending arrangements (“health FSAs”), and certain other employer-sponsored health arrangements.

August 14, 2013

SECOND OPINIONS: Determining Seasonal Worker Exceptions

August 14, 2013 ( – “I have read that an employer who hires agricultural workers on a seasonal basis needs to determine whether the seasonal employee exception applies in order to calculate full-time equivalents (FTEs).

April 24, 2013

SECOND OPINIONS: ACA-Required Deductible & Cost Sharing Limits

April 24, 2013 ( - The Department of Labor (DOL) recently issued a series of FAQs that addressed, among other things, applicability of the deductible and out-of-pocket limits that group health plans are required to implement as of January 1, 2014 under the Affordable Care Act (ACA).

February 13, 2013

SECOND OPINIONS: Proposed Wellness Rules under the ACA

February 13, 2013 ( - At the end of 2012, the Departments of Health and Human Services, Labor, and Treasury issued new proposed wellness rules that, when finalized, will go into effect January 1, 2014.

December 05, 2012

SECOND OPINIONS: PPACA Plan Amendment Checklist

December 5, 2012 - Health care reform has and continues to require a number of plan amendments.  These amendments have varying effective dates and parties to whom they apply.  Below are guidelines for plans to follow when considering which amendments they need to adopt.