IRS Letter 226J: what about the constitutional due process hurdles to collecting employer shared responsibility excise taxes?
This month, the IRS quietly updated Frequently Asked Questions (FAQs) 55-58 regarding employer shared responsibility provisions under the Patient Protection and Affordable Care Act (PPACA) to explain how the IRS is going to start imposing employer shared responsibility excise taxes.
HIPAA Phase 2 Audits Are Here. Are You Ready?
Phase 2 of the U.S. Department of Health and Human Services Office for Civil Rights’ (“OCR”) HIPAA audit program is in process. Unlike OCR’s initial Phase 1 Pilot audits, which addressed only Covered Entities, Phase 2 also focuses on Business Associate compliance with HIPAA’s Privacy, Security, and Breach Notification Rules.