Status Quo for Health Care Reform

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The re-election of President Obama has ensured that the Affordable Care Act will continue to be implemented, including major reforms effective in 2014. Federal and state efforts towards implementing much of the Act's 2014 provisions slowed over the past year due to uncertainty over the Act's future in the face of court challenges and the November elections. Now that the Democrats have kept control of the Senate and the President has won re-election we expect a flurry of activity at both the state and federal level. We should get our first glimpse of what an Iowa statewide exchange may look like on November 16, 2012, the deadline for States to submit their exchange blueprints to the federal government. We are also eagerly awaiting regulations implementing a variety of provisions of concern for employers, including the employer "play or pay" requirements which we hope will provide clearer guidance on a large employer's obligation to provide affordable, minimum value insurance to full-time employees. Other areas we are watching include regulations implementing the small employer health care tax credit in 2014, IRS guidance on the application of the non-discrimination rules to fully-insured non-grandfathered plans, and exchange notices employers must deliver to employees in 2013.

To receive updates on these and other regulatory developments, subscribe to our health care reform blog here.


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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