Delay of Penalties for Employer Shared Responsibility


July 2, 2013, the U.S. Treasury Department posted a blog announcing its intention to delay – until January 1, 2015 -- the imposition of penalties under the Affordable Care Act for large employers that do not offer health insurance for their full-time employees. Penalties under the employer shared responsibility portion of the health care reform law were originally scheduled to take effect as of January 1, 2014.  (A “large” employer under the law is a business with 50 or more full-time equivalent employees).  While this delay raises new questions, employers may wish to consider the following:  

  • “Stay Tuned”.  The Federal government expects to issue more detailed guidance on its delay around penalties and employer shared responsibility “within the next week”.
  • Ripple Effects?  As of today, it is unclear what, if any, effects this delay may have on other aspects of the Affordable Care Act.
  • Time to Prepare.  This extension will provide additional time for strategic and other planning opportunities for employers.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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