ON JULY 2 THE OBAMA ADMINISTRATION ANNOUNCED A ONE YEAR DELAY OF REQUIREMENTS FOR LARGE EMPLOYERS (50 OR MORE FULL-TIME EMPLOYEES) TO REPORT THE HEALTH CARE COVERAGE THEY OFFER THEIR EMPLOYEES, AS WELL AS PENALTIES FOR FAILURE TO OFFER QUALIFIED INSURANCE. THE ADMINISTRATION ALSO ANNOUNCED A DELAY IN INFORMATION REPORTING REQUIREMENTS APPLICABLE TO INSURERS, SELF-INSURING EMPLOYERS, AND OTHER PARTIES THAT PROVIDE HEALTH COVERAGE.

Implementation of the Affordable Care Act (ACA) continues at an accelerated pace. Some of its most important provisions for employers are scheduled to take effect in January 2014. With the force of these provisions now less than a year away, employers need to understand their impact and begin to prepare now to comply with the new requirements. To assist in this effort, we have outlined some of the questions employers will face in preparing for January 2014 and how employers may approach these questions in light of the ACA’s requirements. Note, however, that employers that self-insure are subject to an additional set of requirements not addressed here.

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