January 15, 2015, Compliance Update


2015 Checklist

I am attaching a really comprehensive checklist for various employee benefit plans for this year. Yes, it is hard to believe it is 2015, but it is time to start focusing in on compliance issues.


There are a lot of compliance tools out there, but this one was prepared by a major consulting house and does a really good job of laying out the requirements. I urge you to print it out and keep it handy to reference throughout the year.

Let the Good Times Begin

Here we are in a new year, and the employer mandate or play-or-pay rules kick in for larger employers (i.e. 100 or more full-time and full-time equivalent employees) and some midsized employers (i.e. 50 to 99 full-time and full-time equivalent employees). So what can go wrong? Let me count the ways. Here are a couple of articles that list some of the “hot spots” to consider.



The statute continues to be criticized but it continues to move forward. The US Supreme Court is scheduled to hear another lawsuit involving the premium subsidies. So this is far from over, but you should not take the position that the law is going away. In other words, you need to comply with the rules now!!!!!!!

No Good Deed Goes Unpunished

Employers continue to look for ways to help employees. Oftentimes that focus is on the full- time employees. However, most employers want to try to do something for all the employees, including part-time employees. One way seems to be allowing the part-time employees to contribute to a Health FSA. Doing this costs the employer little, if anything, but the Health FSA may be beneficial to the part-time employees. Unfortunately, there are real issues with offering a Health FSA to part-time employees without allowing them to participate in the “main” group health plan.