In last week’s post on the topic of the recently issued final regulations under the Affordable Care Act’s employer shared responsibility (a/k/a “pay-or-play”) rules, we suggested that the final regulations broke little new ground. Instead, we claimed that the final regulations:
Fixed glitches in the proposed regulations,
Provided some important clarifications of certain provisions of the proposed regulations; and
Extended and expanded the transition rules that were provided in the preamble to the proposed regulations.
In the table available in our latest client advisory, we list our choices of the top 10 changes made to the proposed regulation by the final rules. Items 3 and 5 address and fix glitches; items 1, 2, 4, 6, 7 and 8 provide clarifications; and items 9 and 10 include transition rules.