Updates Regarding Automatic Enrollment, Employer Shared Responsibility, and Waiting Periods in the Affordable Care Act; Additional Feedback Solicited


On February 9, 2012, the U.S. Departments of Labor, Health and Human Services, and Treasury (the Departments) issued FAQs on open questions under the Patient Protection and Affordable Care Act. The FAQs, contained in Notice 2012-17 and Technical Release 2012-01, are available here and here.

Once again signaling a readiness to respond to employer comments and concerns, the Departments have provided a provisional update on rulemaking in three areas and solicited additional comments from interested parties.

Automatic Enrollment

The Affordable Care Act requires employers of at least 200 full-time employees to automatically enroll eligible employees and automatically continue employees’ enrollments, unless they opt out of coverage. The FAQs provide that the Department of Labor will not be ready to issue guidance on this provision prior to 2014 and reiterate that employers will not be required to comply until final regulations have been issued and take effect.

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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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