We recently advised that federal Health Care Reform imposed new nondiscrimination rules on health plans that would require a major overhaul of many management and executive plans. [Link to previous article] Health Care Reform requires compliance with these new rules beginning the first day of the first plan year on or after 9/23/2010.

Last week, the IRS issued Notice 2011-1, delaying the implementation of enforcement of the nondiscrimination provisions of the Act until guidance on how to implement the new law is issued. The IRS, Department of Labor, and Department of Health and Human Services (the 3 regulators that enforce Health Care Reform) all agreed to the delay.