On January 24, the Departments of Labor, Health and Human Services, and the Treasury (the Departments) released the eleventh in a series of frequently asked questions and answers (FAQs) regarding the implementation of the Affordable Care Act (the Act).

Most notably, the FAQs announce a delay in the first date by which employers must distribute certain information about health insurance exchanges to current and new employees from March 1, 2013 to an unspecified date in the late summer or fall of 2013 that will coordinate with the open enrollment period for the exchanges. In addition, the FAQs provide additional guidance on the compliance of health reimbursement arrangements (HRAs) with the Act’s general prohibition on plans and issuers imposing lifetime or annual limits on the dollar value of essential health benefits.

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