Compliance Alerts: CMS Reinsurance Filing Status Requests and LGBT Worker Protections

Information Requests from CMS Regarding Reinsurance Contributions

Centers for Medicaid and Medicare Services (CMS) is contacting group health plans for whom they have not been able to locate an “ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form” for the 2014 benefit year. They are requesting that plans provide information to confirm the status of their Form filing so that CMS can reconcile their records.

Protections for Lesbian, Gay, Bisexual, Transgender (LGBT) Workers

The Equal Employment Opportunity Commission (EEOC) has instructed its investigators and attorneys to counsel individuals who believe they have been discriminated against because of their sexual orientation or transgender status that they may file a complaint of sex discrimination under Title VII. The memorandum lists insurance issues involving benefits for same-sex couples as an issue of particular interest to the EEOC.

IRS Releases Draft 2015 Forms 1094-C and 1095-C

Last week, the IRS issued draft 2015 Forms 1094-C and 1095-C. The forms are substantially the same as the 2014 forms, except for a couple of changes, as noted in the attached update. Further guidance will be welcome, and we are watching for the draft instructions to be released. However, it is encouraging to see that the regulators did not contemplate significant changes from the 2014 forms. Once finalized, these are the forms that will be used for calendar year 2015 reporting, due in early 2016

If you have any questions, contact your USI representative of the Northeast employee benefits office near you.

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