News & Analysis as of

Pay or Play Deadlines Delays

Cozen O'Connor

Health Care Reform Implementation Update - August 19, 2013

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With less than 50 days until open enrollment begins, tensions in Washington and around the country are high among health care stakeholders. ...more

Snell & Wilmer

Government Agencies Release Additional Guidance on Minimum Essential Coverage, Minimum Value and Summary of Benefits and Coverage

Snell & Wilmer on

As discussed in our March 20, 2013 Legal Alert – Health Care Reform’s Large Employer Play or Pay Penalties: A Checklist for Employers, large employers will be subject to a penalty tax if they either: (1) fail to offer...more

BakerHostetler

Now for Everything Else: What Employers Still Need To Worry About Between Now And 2015

BakerHostetler on

For the past several months (and, in many cases, years), most large employers have been preparing for the consequences of offering (or not offering) their workforce health coverage and complying with the complexities...more

Poyner Spruill LLP

Employer Responsibility – Will You Pay or Play? Part II - The Variable Hour or Seasonal Employee Problem

Poyner Spruill LLP on

Although the employer mandate has been delayed to 2015, employers shouldn’t relax too much because significant planning still needs to be done now. Beginning in 2015 large employers either must offer full-time employees...more

Mintz - Employment, Labor & Benefits...

Cafeteria Plans, the Affordable Care Act, and Continued Compliance with the Massachusetts Free-Rider Surcharge Requirement—New...

Established as a part of the comprehensive 2006 Massachusetts health care reform law, the Massachusetts Health Insurance Connector (a/k/a the “Connector”) served as a model for the American Health Benefit Exchanges that are a...more

Fisher Phillips

Benefits Update, No. 3, August 2013: Healthcare Reform: What Was and Was Not Delayed?

Fisher Phillips on

On July 2, 2013, the U.S. Treasury Department delayed enforcement of the employer “play or pay” mandate penalties and reporting requirements one year to 2015, stating that covered employers should still comply with the...more

Franczek P.C.

Monthly Benefits Update - July 2013

Franczek P.C. on

Health Care Reform: IRS Transitional Relief Delays Pay or Play Reporting and Penalties - As we reported in an alert on July 3, the IRS has provided transitional relief to employers that delays pay or play reporting and...more

Cozen O'Connor

Health Care Reform Implementation Update - July 23, 2013

Cozen O'Connor on

With only two weeks before Congress’ August recess and just a little more than two months before October open enrollment begins, Washington is busy sorting through, implementing and, in some cases, fighting the Affordable...more

Wilson Sonsini Goodrich & Rosati

U.S. Treasury Department Delays Enforcement of Employer Mandate and Reporting Requirements Under PPACA

As seen in many mainstream press reports, the Obama administration announced in early July that (1) the employer mandate and (2) certain reporting requirements under the Patient Protection and Affordable Care Act (PPACA) will...more

Mintz - Health Care Viewpoints

Caution: Risk Adjustment Hurdles Facing Plans and Providers Under the Affordable Care Act

January 1, 2014 is fast approaching and regulators, payor organizations, providers, and many other interested parties are working to implement, operationalize, and participate in the state-based American Health Benefit...more

Ervin Cohen & Jessup LLP

ACA Responsibility Payments, Mandatory Employer and Insurer Requirements Delayed

Those of you just arriving on the planet may have heard a little something about the Affordable Care Act and the fact that it has a lot of folks worried about just how it will all work....more

Foley & Lardner LLP

ACA’s “Pay-Or-Play” Penalty Delayed Until 2015

Foley & Lardner LLP on

Last week, in a move welcomed by many employers, the Obama administration announced that it would delay implementation of certain key provisions of the Affordable Care Act (ACA) until 2015....more

Pillsbury - Global Sourcing Practice

Obamacare: Meeting Implementation Challenges with Contracting Best Practices

The Affordable Care Act of 2010 mandated the creation of health care exchanges ("Exchanges") which will enable individuals to shop on-line for health insurance beginning October 1, 2013....more

Orrick - Employment Law and Litigation

The Affordable Care Act – Consider Yourself on Notice

Under the Affordable Care Act, employers subject to the Fair Labor Standards Act must provide a “Notice of Coverage Options” to each employee. The purpose of this Notice is to inform employees that they may obtain health...more

Mintz - Employment, Labor & Benefits...

It’s Official: IRS Issues Guidance Affirming One-Year Delay in the Affordable Care Act Employer Mandate and Related Reporting...

On July 9, less than a week after the Obama administration announced a one-year delay in the enforcement of the employer shared responsibility (aka “pay-or-play”) rules,1 the IRS has issued guidance making the move official....more

FordHarrison

Legal Alert: Guidance Released On Delay Of "Pay Or Play" Penalties Under ACA

FordHarrison on

The Obama Administration has released formal guidance on the delay of the Affordable Care Act's (the "ACA") employer mandate and certain reporting requirements. ...more

Laner Muchin, Ltd.

Employers Face Compliance Options In Lights Of Delayed Implementation Of Pay Or Pay Mandate Under The ACA, But Other ACA...

Laner Muchin, Ltd. on

On July 2, 2013, the Treasury Department’s announced that enforcement of the "Pay or Play" mandate under the ACA will be delayed until January 1, 2015. This announcement was followed by a brief notice from the IRS which...more

Eversheds Sutherland (US) LLP

Legal Alert: IRS Issues Transition Relief Guidance on PPACA Reporting and Employer Penalty

On July 9, the Internal Revenue Service (IRS) released Notice 2013-45 (the Notice), granting transition relief from the “Employer Shared Responsibility” provisions and certain health plan reporting requirements under the...more

Dickinson Wright

IRS Issues Transition Relief On The One-Year Delay In PPACA’s Information Reporting And Employer Shared Responsibility Rules

Dickinson Wright on

Late on July 9, 2013, the IRS issued Notice 2013-45 which provides some additional information regarding the Department of Treasury’s recently announced delay in the information reporting and employer shared responsibility...more

Best Best & Krieger LLP

IRS Guidance Released on the Delayed Implementation of the Affordable Care Act's Play or Pay Rules - Penalties Will Not Apply to...

On the heels of last week’s announcement that the Affordable Care Act’s (ACA) reporting requirements and Play or Pay penalties will not go into effect until 2015, the IRS has released transition relief clarifying that the...more

Mintz - Employment, Labor & Benefits...

Obama Administration Delays Enforcement of the ACA Employer Shared Responsibility Rule to 2015

In a move that took many by surprise, the Obama Administration on July 3 announced a one-year delay (to January 1, 2015 from January 1, 2014) in the enforcement of the employer mandate under the Patient Protection and...more

Saul Ewing Arnstein & Lehr LLP

Provisions of Affordable Care Act Could Impact Tax-Exempt Status of Certain Bonds

Certain payment models created under the Patient Protection and Affordable Care Act intended to coordinate care and lower healthcare costs raise questions concerning the tax-exempt status of debt issued by certain healthcare...more

Carlton Fields

Affordable Care Act’s Reporting Requirements And Employer Mandate Postponed Until 2015; New IRS Guidance Released

Carlton Fields on

On July 2 the Obama Administration announced delays of the Patient Protection and Affordable Care Act’s (“ACA”) mandatory employer and insurer reporting requirements, and the requirement that all but the smallest employers...more

Polsinelli

ACA "Pay Or Play" Deadline Extension — What It REALLY Means

Polsinelli on

On July 2, 2013, the U.S. Treasury announced that the Obama Administration is implementing a one-year delay of the employer and insurer reporting requirements under the Affordable Care Act of 2010 ("ACA"). ...more

Mintz - Health Care Viewpoints

Health Care Reform Update -- July 8, 2013

In This Issue: Leading the News; Implementation of the Affordable Care Act; Other HHS and Federal Regulatory Initiatives; Other Congressional and State Initiatives; and Hearings and Mark-Ups Scheduled. Excerpt...more

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