Late on July 9, 2013, the IRS issued Notice 2013-45 which provides some additional information regarding the Department of Treasury’s recently announced delay in the information reporting and employer shared responsibility provisions of PPACA. Notice 2013-45 does not provide much in the way of substantive detail other than to confirm the delay in the implementation of these requirements and relief from penalties for not complying with these requirements in 2014. Specifically, the Notice provides:
• The IRS expects to issue proposed rules later this summer related to the information reporting that employers sponsoring self-insured group health plans, insurers and certain others have to make under Code Section 6055 related to the minimum essential coverage they offer and that applicable large employers have to make under Code Section 6056 related to the coverage offered to full-time employees. Once the proposed rules are issued, the IRS encourages employers, insurers and others to voluntarily comply with the rules for 2014 (by filing reports in 2015 related to 2014). The IRS notes that real world testing of reporting systems and plan designs through voluntary compliance for 2014 will help with a smoother transition to full implementation for 2015. However, there will be no penalty for not voluntarily reporting as suggested by the IRS.
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