Employer Pay or Play Mandate Delayed for One Year

Yesterday the Treasury Department announced a one-year delay of the Pay or Play rules and the Pay or Play reporting requirements on employers. Penalties for not offering coverage to full-time employees and dependents, and penalties for not offering affordable, minimum value coverage have been delayed until 2015. The Treasury Department noted that their actions do not affect access to premium tax credits, the individual mandate or any other provision of the ACA. Formal guidance implementing the delay is to be published next week. (The PCORI tax, the temporary reinsurance fee, the 90-day limitation on waiting periods, the prohibition on preexisting condition exclusions, the Exchange Notice, as well as other health insurance reforms have NOT been given a one-year delay in this announcement so please make sure you are meeting these requirements where applicable.)

According to the announcement, the one-year delay is designed to meet two goals. First, it will provide time to simplify the new reporting requirements. Second, it will provide time to adapt health coverage and reporting systems while employers move toward adjusting health coverage to be compliant.

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Please contact me with any questions: Marcia Goggin