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Recently, the Metropolitan Transportation Commissions (MTC) and the Bay Area Air Quality Management District (BAAQMD) approved the Bay Area Commuter Benefits Program. The program requires Bay Area employers (private sector, public sector, and non-profit), with 50 or more full time employees, to offer one of four Commuter Benefits options. Counties that are subject to this requirement include Alameda, Contra Costa, Marin, Napa, San Francisco, Santa Clara, San Mateo, the southern portion of Sonoma and the western portion of Solano. The program must be implemented by September 30, 2014.

The recently released IRS final regulations on the Affordable Care Act (ACA) 4980H employer shared responsibility rules (often called the “pay or play” rules) largely formalized the rules previously described in proposed regulations originally released in January 2013. The new rules, however, contain important new guidance and clarifications regarding the definition of a full-time employee, including employer’s use of the optional look-back measurement period approach and counting hours of service.

On Friday, May 2, 2014, I’ll be speaking on a panel with colleagues in Palo Alto, California, at Sidley Austin LLP to discuss what companies should be doing if they’re considering an IPO. Join me, along with Justin Bastian from Sidley Austin; Cully Davis of Credit Suisse; Jim Neesen at The Connor Group; and moderator Karen Dreyfus of Sidley Austin as we take part in this interactive discussion.

The IRS released guidance March 28, 2014, via a memo from the Office of Chief Counsel in regard to the health flexible spending account (FSA) carryover (up to $500) and health savings account (HSA) eligibility. The guidance clarifies methods under which an employer may implement the carryover provision, first introduced under guidance provided in 2013, while allowing individuals to maintain eligibility for HSA contributions.

On April 1, 2014, the President signed into law the Protecting Access to Medicare Act of 2014. The bulk of the provisions relate to Medicare; however, the law also contained a provision repealing the limitation on deductibles that applied to fully-insured small group plans under the Affordable Care Act (ACA).