Obama Administration to Delay Employer Reporting Requirements and ‘Shared Responsibility’ Payments until 2015


On July 2, 2013, the Obama Administration (“Administration”) announced that it will delay the mandatory reporting requirements for employers and health insurers under the Patient Protection and Affordable Care Act (“ACA”) until January 1, 2015. The reporting requirements were originally scheduled to begin January 1, 2014.

In addition, the Administration announced that the “shared responsibility” payments (commonly referred to as the “employer mandate”) added by the ACA will not apply until January 1, 2015. The “shared responsibility” payments were originally scheduled to begin January 1, 2014. Pursuant to this requirement of the ACA, the IRS could have required certain employers with 50 or more full-time employees or full-time equivalent employees, that do not offer health coverage or that offer health coverage that is unaffordable or does not provide minimum value to their full-time employees and dependents, to pay an excise tax in 2014. The delay by one year of the “shared responsibility” payments is welcome relief for employers feeling overwhelmed by the requirements of the ACA.

Even though the reporting requirements and “shared responsibility” penalties are delayed until 2015, the Administration strongly encourages employers to maintain or expand health coverage, and voluntarily implement the reporting requirements in 2014 in preparation for the full application of the requirements.

Formal guidance describing the transition relief is scheduled to be provided within the next week.

If you have questions or comments about the announcement or the ACA, please contact one of the authors.

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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