The U.S. Department of Labor (DOL) released a new model employer Children’s Health Insurance Program (CHIP) notice with information that is current as of July 31 .   Under the Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA), employers maintaining group health plans in states that provide premium assistance subsidies under a Medicaid plan or a CHIP plan must send employees an annual notice.   An employer can choose to provide the notice on their own or concurrent with the furnishing of:   materials notifying the employee of health plan eligibility;  open enrollment materials; and  the summary plan description.  An employer is subject to this annual notice requirement if their group health plan covers participants who reside in a state that provides a premium assistance subsidy, regardless of the employer’s location.   Employers may use the DOL’s model notice for this disclosure. DOL updates the model notice periodically to reflect changes in the states that offe

IRS releases ACA pay –or play penalties for 2025  The IRS recently updated  “pay or play” penalty amounts for 2025 related to the Affordable Care Act’s employer shared responsibility rules.   For calendar year 2025, the annually adjusted $2,000 penalty amount is $2,900 and the adjusted $3,000 penalty amount is $4,350 . This is a decrease from the penalty amounts for the 2024 calendar year, which are $2,970 and $4,460, respectively.  Under the pay or play rules, an applicable large employer is only liable for a penalty if at least one full-time employee receives a subsidy for Exchange coverage. Employees who are offered affordable, minimum-value coverage are generally not eligible for these Exchange subsidies.  Depending on the circumstances, one of two penalties may apply under the pay or play rules: the Section 4980H(a) penalty or the Section 4980H(b) penalty:  Under Section 4980H(a) an applicable large employer will be subject to a penalty if it does not offer coverage to “substa